22 CFR §121.1 Category XI
USML Category XI: Military Electronics
USML Category XI is a broad category capturing electronic systems and equipment specifically designed for military applications — including electronic warfare systems, military communications and information systems, intelligence-gathering equipment, and countermeasure devices. The category covers both complete systems and components that are specially designed for or militarily critical to these applications.
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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 XI covers
USML Category XI is a broad category capturing electronic systems and equipment specifically designed for military applications — including electronic warfare systems, military communications and information systems, intelligence-gathering equipment, and countermeasure devices. The category covers both complete systems and components that are specially designed for or militarily critical to these applications.
Common controlled items
- Jamming systems and electronic countermeasure (ECM) equipment
- Military communications encryption devices (NSA Type 1 certified)
- Electronic intelligence (ELINT) and signals intelligence (SIGINT) collection systems
- Spread-spectrum communications and frequency-hopping military radios
- Military IFF (Identification Friend or Foe) systems (Mark XII, Mode 5)
- Electronic warfare threat libraries and signal analysis systems
- Military radar jamming pods and self-protection suites
EAR / ECCN
EAR overlap
Commercial telecommunications and general-purpose electronics are widely controlled under EAR (ECCN 5A001, 5E001 series). Military electronics become ITAR-controlled when they incorporate militarily critical performance parameters — such as specific anti-jam margins, resistance to electromagnetic pulse (EMP), or designed-in interoperability with NSA Type 1 encryption.
Licensing
Typical license requirements
DSP-5 licenses required. Technical Assistance Agreements (TAAs) or Manufacturing License Agreements (MLAs) are needed for co-development arrangements. NSA-controlled cryptographic items may require separate NSA authorization in addition to DDTC export licensing.
Regulations
Key citations
22 CFR §121.1 Category XI22 CFR §124 — Defense Services and Agreements22 CFR §125 — Technical Data LicensesNSA/CSS Policy 6-22 for cryptographic items
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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