USML Category II: guns and armament

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1. Guns above .50 caliber

Category II of the United States Munitions List (USML), the list set out in the International Traffic in Arms Regulations (ITAR), is headed "Guns and Armament" (22 CFR 121.1). Where Category I stops at .50 caliber (12.7 mm), paragraph (a) of Category II starts above it. It covers guns, howitzers, artillery and cannons, mortars, recoilless rifles and grenade launchers, all greater than .50 caliber, and each of those four groups carries an asterisk. Firearms up to that size are covered in Category I, firearms and related articles.

Each asterisk marks Significant Military Equipment (SME) (22 CFR 120.10).

A note sets out what paragraph (a) leaves to the Commerce Department’s list (22 CFR 121.1). It excludes non-automatic and non-semi-automatic rifles, carbines and pistols between .50 (12.7 mm) and .72 caliber (18.288 mm), controlled under Export Control Classification Number (ECCN) 0A501. It also excludes shotguns under ECCN 0A502, black powder guns and armaments made between 1890 and 1919 under ECCN 0A602, and black powder guns made earlier than 1890. Those ECCNs sit on the Commerce Control List of the Export Administration Regulations (EAR) (22 CFR 121.0).

Two points follow from the regulations’ general rules. Technical data directly related to the manufacture or production of an asterisked gun is itself SME (22 CFR 120.10). And no Category II entry carries the (MT) annotation used for missile-related items (22 CFR 121.1).

2. Developmental guns

Paragraph (a)(5) reaches developmental guns and armament greater than .50 caliber (12.7 mm) funded by the Department of Defense, and their specially designed parts and components (22 CFR 121.1). It does not control such guns once they are in production, or if a commodity jurisdiction determination has placed them under the EAR. Nor does it control guns identified in the Defense Department contract or funding authorization as being developed for both civil and military applications. Those exclusions do not apply to articles enumerated elsewhere on the USML, whether in production or development. The provision applies to contracts and funding authorizations dated January 23, 2021, or later.

3. Where a gun sits depends on its carrier

A second note sorts guns by how they are mounted (22 CFR 121.1). Guns and armament integrated into their carrier, such as a surface vessel, ground vehicle or aircraft, are controlled in the category for that carrier. Self-propelled guns and armament are controlled in Category VII. Towed and stand-alone guns and armament stay in Category II. The same logic appears in the parts paragraph, which sends weapons mounts specially designed for surface vessels to Category VI and those for ground vehicles to Category VII.

4. Flamethrowers and kinetic energy weapons

Paragraph (b) covers flamethrowers with an effective range greater than or equal to 20 meters (22 CFR 121.1). Paragraph (c) is reserved. Paragraph (d), marked with an asterisk, covers kinetic energy weapon systems specially designed for destruction or rendering mission-abort of a target. A note says these include launch systems and subsystems capable of accelerating masses larger than 0.1g to velocities in excess of 1.6 km/s, in single or rapid fire modes. The methods named are electromagnetic, electrothermal, plasma, light gas or chemical. Launch systems used for research and testing facilities subject to the EAR are excluded, and fall under ECCN 2B232.

Paragraph (e) covers signature reduction devices specially designed for the guns and armament in paragraphs (a), (b) and (d), with muzzle flash suppression devices given as the example (22 CFR 121.1). Paragraphs (f) to (i) are reserved.

5. Parts, components and accessories

Paragraph (j) lists seventeen groups of parts, components, accessories and attachments (22 CFR 121.1). For the weapons in paragraphs (a) and (d), it covers specially designed gun barrels, rails, tubes and receivers, together with breech blocks and firing mechanisms. It also covers sights specially designed to orient indirect fire weapons, and systems for firing superposed or stacked ammunition. Servo-electronic and hydraulic elevation adjustment mechanisms, muzzle brakes and bore evacuators appear without further qualification.

Ammunition handling takes up several entries (22 CFR 121.1). They cover independent ammunition handling systems, and mounts, carriages, gun pallets and hydro-pneumatic equilibration cylinders for independently powered systems. Hydro-pneumatic systems able to scavenge recoil energy to power howitzer functions are included, as are specially designed ammunition containers, drums, chutes, conveyor elements and feeder systems. Equipment for programming ammunition for the weapons in paragraphs (a) and (d) is listed as well.

Three entries concern aircraft and kinetic weapons (22 CFR 121.1). They are aircraft and gun interface units for gun systems with a designed rate of fire greater than 100 rounds per minute, and recoil systems specially designed for guns integrated into air platforms. The third is power generation, energy storage, thermal management and related equipment specially designed for the kinetic weapons in paragraph (d). Kinetic energy weapon target acquisition, tracking fire control and damage assessment systems are also covered.

The last entry, marked with an asterisk, catches any part, component, accessory, attachment, equipment or system that is classified, contains classified software, or is being developed using classified information (22 CFR 121.1). A part or accessory generally counts as specially designed if it is for use in or with a defense article, though fasteners, springs and similar hardware are carved out (22 CFR 120.41).

6. Technical data and the EAR paragraph

Paragraph (k) controls technical data and defense services directly related to the articles in paragraphs (a), (b), (d), (e) and (j) (22 CFR 121.1). It also controls classified technical data directly related to items in ECCNs 0A602, 0B602, 0D602 and 0E602, and defense services using that data. Paragraphs (l) to (w) are reserved. As elsewhere on the list, paragraph (x) provides for Commerce-controlled items bought together with the guns.

Key terms

Guns and armament	Guns, howitzers, artillery, cannons, mortars, recoilless rifles and grenade launchers above .50 caliber.
Developmental gun	A gun above .50 caliber funded by the Defense Department and not yet in production.
Kinetic energy weapon	A system that accelerates masses to very high velocity to destroy a target or force a mission abort.
Carrier rule	The note placing integrated guns in the category of the vessel, vehicle or aircraft that carries them.
Significant Military Equipment (SME)	Items in paragraphs marked with an asterisk, subject to special export controls.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

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