22 CFR §121.1 Category X
USML Category X: Personal Protective Equipment and Shelters
USML Category X covers personal protective equipment and collective protection systems designed specifically for military environments, including body armor meeting military specifications, nuclear-biological-chemical (NBC) protective gear, and deployable shelters engineered for military operations. The category captures both individual soldier protection and mission-critical protection systems whose performance specifications are driven by military requirements.
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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 X covers
USML Category X covers personal protective equipment and collective protection systems designed specifically for military environments, including body armor meeting military specifications, nuclear-biological-chemical (NBC) protective gear, and deployable shelters engineered for military operations. The category captures both individual soldier protection and mission-critical protection systems whose performance specifications are driven by military requirements.
Common controlled items
- Military-specification body armor systems (Interceptor, IOTV, ESAPI plates)
- Military ballistic helmets (ACH, ECH) and hearing protection
- CBRN (chemical, biological, radiological, nuclear) protective suits and masks
- NBC collective protection systems for command post shelters
- Military deployable shelters and hardened bunker systems
- Fragmentation-resistant and ballistic-resistant vehicle crew protection
- Military blast-resistant footwear and EOD protective suits
EAR / ECCN
EAR overlap
Commercial body armor not meeting military specifications may be controlled under EAR ECCN 1A005. Military-specification protective equipment — particularly CBRN gear or armor meeting NIJ Level IV or ESAPI standards as described in military specifications — is generally ITAR-controlled. Export of body armor to civilian end-users in certain countries is also subject to Commerce Department review.
Licensing
Typical license requirements
DSP-5 licenses required for Category X exports. Body armor exports are subject to additional policy scrutiny given proliferation concerns. CBRN protective equipment exports to foreign military forces typically require end-use certificates and post-shipment verification.
Regulations
Key citations
22 CFR §121.1 Category X22 CFR §123 — Export Licenses15 CFR §742.2 — Regional Stability (EAR overlap for body armor)
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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