22 CFR §121.1 Category III
USML Category III: Ammunition/Ordnance
USML Category III covers ammunition and ordnance for weapons controlled in Categories I and II — including military cartridges, shells, propellants, explosives, and their components designed for use in military weapons. The category spans from small-arms ammunition with military characteristics to large-caliber projectiles, as well as ammunition cases and primers that are specially designed for military use.
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Founder, ITAR Screen
Trenton is the founder of ITAR Screen and Gideon Dynamics. He built ITAR Screen to give defense contractors and dual-use exporters fast, auditable USML classification and denied-party screening without the complexity of enterprise compliance platforms.
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Coverage
What Category III covers
USML Category III covers ammunition and ordnance for weapons controlled in Categories I and II — including military cartridges, shells, propellants, explosives, and their components designed for use in military weapons. The category spans from small-arms ammunition with military characteristics to large-caliber projectiles, as well as ammunition cases and primers that are specially designed for military use.
Common controlled items
- Armor-piercing, tracer, incendiary, and explosive small-arms ammunition
- Artillery shells and projectiles (105 mm, 155 mm, and larger)
- Mortar rounds and illuminating projectiles
- Anti-tank rockets and rocket-propelled grenade (RPG) rounds
- Military blank and drill cartridges with military design features
- Linked-belt ammunition and disintegrating-link assembly systems
- High-explosive (HE) and dual-purpose improved conventional munitions (DPICM)
EAR / ECCN
EAR overlap
Commercial sporting ammunition (e.g., standard hunting or target rounds) is controlled under EAR ECCN 0A505. Military-specification ammunition — particularly armor-piercing, tracer, or explosive rounds — is ITAR-controlled under Category III regardless of apparent commercial availability.
Licensing
Typical license requirements
DSP-5 licenses are required for exports. Ammunition exports to foreign governments are frequently handled through FMS channels. Certain exemptions exist for returning personal defense weapons with limited ammunition quantities under 22 CFR §123.17.
Regulations
Key citations
22 CFR §121.1 Category III22 CFR §123.17 — Exemptions for Personal Weapons and Ammunition22 CFR §123 — Export Licenses
Always verify against the current version of the USML (22 CFR Part 121) on the eCFR. ITAR Screen classifications are versioned against the USML reference at the time of the call.
Primary sources
- DDTC — 22 CFR Parts 120–130 (ITAR)
Official ITAR text administered by the State Dept. Directorate of Defense Trade Controls
- BIS — 15 CFR Parts 730–774 (EAR)
Export Administration Regulations, including the Commerce Control List (CCL)
- OFAC — Sanctions Programs and Country Information
Current SDN list, blocked persons, and active U.S. Treasury sanctions programs
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