22 CFR §121.1 Category XV
USML Category XV: Spacecraft Systems and Associated Equipment
USML Category XV covers spacecraft, satellites, and associated systems designed or modified for military or national security applications, as well as ground control systems and components with performance specifications suited to military space operations. The category includes both military and dual-use space systems, and its application to commercial satellites has historically been a significant area of policy debate, particularly following the transfer of commercial satellites from ITAR to EAR control.
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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 XV covers
USML Category XV covers spacecraft, satellites, and associated systems designed or modified for military or national security applications, as well as ground control systems and components with performance specifications suited to military space operations. The category includes both military and dual-use space systems, and its application to commercial satellites has historically been a significant area of policy debate, particularly following the transfer of commercial satellites from ITAR to EAR control.
Common controlled items
- Military reconnaissance and surveillance satellites (ISR satellites)
- Military communications satellites (MILSATCOM)
- GPS satellite payloads and military signal processing equipment
- Satellite command and control ground systems for military space
- Space launch vehicle upper stages optimized for classified payload deployment
- Military space situational awareness (SSA) systems
- Radiation-hardened electronics designed for military space environments
EAR / ECCN
EAR overlap
Following the Export Control Reform Act (ECRA) of 2018 and related regulatory changes, many commercial communication satellites were transferred from ITAR Category XV to EAR ECCN 9A515. Satellites designed primarily for military or national security applications remain ITAR-controlled. The distinction requires careful technical and policy review.
Licensing
Typical license requirements
Satellite exports require DSP-5 licenses and, for launches from foreign territories, Presidential Determination under Section 1512 of the Strom Thurmond Act. DDTC coordinates with the intelligence community for national security space system transfers. Classified satellite components require separate classified license authority.
Regulations
Key citations
22 CFR §121.1 Category XV22 CFR §123 — Export Licenses22 U.S.C. §2778 — Arms Export Control ActNDAA Section 1512 — Satellite Launch licensing
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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