22 CFR §121.1 Category VI
USML Category VI: Vessels of War and Special Naval Equipment and Associated Equipment
USML Category VI covers naval warships, combat vessels, and specially designed naval equipment not captured by the submersible vessel category (Category XX). This includes surface combatants, amphibious assault ships, naval command vessels, and the specialized equipment that arms, protects, or enables their operation — including torpedo tubes, depth charge projectors, sonar-defeating hull coatings, and ship-launched weapons systems.
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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 VI covers
USML Category VI covers naval warships, combat vessels, and specially designed naval equipment not captured by the submersible vessel category (Category XX). This includes surface combatants, amphibious assault ships, naval command vessels, and the specialized equipment that arms, protects, or enables their operation — including torpedo tubes, depth charge projectors, sonar-defeating hull coatings, and ship-launched weapons systems.
Common controlled items
- Destroyers, frigates, cruisers, and corvettes
- Amphibious assault ships and landing craft
- Naval patrol and fast attack boats with military armament
- Ship-launched torpedo tubes and anti-submarine warfare (ASW) systems
- Degaussing systems for magnetic mine countermeasures
- Naval communications and combat information center (CIC) systems
- Armored pilot houses and weapons-mounting deck systems
EAR / ECCN
EAR overlap
Commercial vessels, including offshore patrol vessels without military armament, may be subject to EAR controls under ECCN 8A609. Conversion of a commercial vessel to carry military weapons or countermeasure systems typically pulls the article into ITAR jurisdiction under Category VI.
Licensing
Typical license requirements
DSP-5 licenses required. Naval vessel exports to foreign governments are typically processed through FMS or Direct Commercial Sale (DCS) with end-use monitoring agreements. Ship transfers are subject to Congressional notification for major defense equipment under the Arms Export Control Act.
Regulations
Key citations
22 CFR §121.1 Category VI22 CFR §123 — Export Licenses22 U.S.C. §2796 — Naval Vessels transfer restrictions
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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