22 CFR §121.1 Category IX
USML Category IX: Military Training Equipment
USML Category IX covers military training systems and equipment specifically designed to train personnel in the use and operation of defense articles controlled elsewhere in the USML. This includes flight simulators for military aircraft, crew training devices for weapons systems, and combat simulation systems that replicate military operational environments. The category focuses on training equipment whose design is tied to controlled military systems.
Reviewed by
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.
Last reviewed:
Coverage
What Category IX covers
USML Category IX covers military training systems and equipment specifically designed to train personnel in the use and operation of defense articles controlled elsewhere in the USML. This includes flight simulators for military aircraft, crew training devices for weapons systems, and combat simulation systems that replicate military operational environments. The category focuses on training equipment whose design is tied to controlled military systems.
Common controlled items
- Full-flight simulators for military aircraft (F-16, Apache)
- Weapons system trainers for guided missile systems
- Tank and armored vehicle crew simulation systems
- Naval combat information center (CIC) trainers
- Military small-arms marksmanship trainers with force-on-force capabilities
- Integrated battle staff training systems with live-virtual-constructive environments
- Anti-aircraft and air defense system operators trainers
EAR / ECCN
EAR overlap
Commercial flight simulators for civilian aircraft are EAR-controlled under ECCN 9A992. A simulator specifically designed for a military aircraft type — particularly one that replicates classified avionics or weapons employment — will be ITAR-controlled under Category IX. Simulators designed for dual-use aircraft require careful classification review.
Licensing
Typical license requirements
DSP-5 licenses are required for training equipment exports. Defense services (instruction, maintenance) associated with Category IX equipment require Technical Assistance Agreements (TAAs) under 22 CFR §124. Training programs for foreign personnel on ITAR-controlled systems also require DDTC authorization.
Regulations
Key citations
22 CFR §121.1 Category IX22 CFR §124 — Agreements and Defense Services22 CFR §125 — Licenses for the Export of Technical Data and Classified Defense Articles
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
Classify a product
Does your product fall under Category IX?
Results include USML citation, risk level, and EAR cross-check
Ready to classify your Category IX product?
USML citations, risk levels, EAR cross-check, and a 10-year screening record — in seconds.
View pricing