22 CFR §121.1 Category VII
USML Category VII: Tanks and Military Vehicles
USML Category VII covers ground combat vehicles designed or modified for military use — including main battle tanks, armored personnel carriers, infantry fighting vehicles, and wheeled combat vehicles. It captures both complete platforms and specially designed components including armor packages, turret drive systems, fire suppression systems, and military-specification automotive components not available in commercial markets.
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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 VII covers
USML Category VII covers ground combat vehicles designed or modified for military use — including main battle tanks, armored personnel carriers, infantry fighting vehicles, and wheeled combat vehicles. It captures both complete platforms and specially designed components including armor packages, turret drive systems, fire suppression systems, and military-specification automotive components not available in commercial markets.
Common controlled items
- Main battle tanks (M1 Abrams series, Leopard 2)
- Armored personnel carriers (M113, Bradley IFV)
- Mine-resistant ambush-protected (MRAP) vehicles
- Military wheeled armored vehicles (Stryker, JLTV)
- Military-specification ballistic armor kits for vehicle add-on protection
- Tank gun stabilization and fire control systems
- Active protection systems (Trophy, Iron Fist) for armored vehicles
EAR / ECCN
EAR overlap
Unarmored military utility vehicles (such as standard HMMWVs without armor) may fall under EAR ECCN 0A606 if not meeting the armored vehicle threshold of Category VII. When in doubt, DDTC's commodity jurisdiction (CJ) process should be used to determine whether a vehicle is ITAR or EAR controlled.
Licensing
Typical license requirements
Exports require DSP-5 licenses. Major defense equipment (MDE) tank transfers require Congressional notification at threshold values. End-use monitoring and Defense Security Cooperation Agency (DSCA) involvement is typical for government-to-government transfers.
Regulations
Key citations
22 CFR §121.1 Category VII22 CFR §123 — Export Licenses22 CFR §130 — Political Contributions, Fees and Commissions
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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