USML Category III: ammunition and ordnance

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1. Ammunition on the list

Category III of the United States Munitions List (USML), which forms part of the International Traffic in Arms Regulations (ITAR), is headed "Ammunition and Ordnance" (22 CFR 121.1). It names the kinds of ammunition that are defense articles, by projectile, by construction or by the weapon the round is made for. Every one of the first nine ammunition entries in paragraph (a) carries an asterisk, the mark of Significant Military Equipment (SME) (22 CFR 120.10). The guns this ammunition feeds are covered in Category II, guns and armament.

2. The nine ammunition entries

The first three turn on the projectile (22 CFR 121.1). Paragraph (a)(1) covers ammunition incorporating a projectile controlled in paragraph (d)(1) or (3), meaning tracer, incendiary or explosive projectiles and depleted uranium projectiles. Paragraph (a)(2) covers ammunition preassembled into links or belts. Paragraph (a)(3) covers shotgun ammunition with a projectile from paragraph (d)(2), meaning flechettes and incendiary, tracer or explosive shotgun projectiles.

The next group turns on construction (22 CFR 121.1). Paragraph (a)(4) covers caseless ammunition manufactured with smokeless powder, the same kind of round defined in Category I. Paragraph (a)(5) covers ammunition, other than shotgun ammunition, on non-metallic cases or cases with only a metallic base. It applies where the result is a total cartridge mass of 80% or less of a brass or steel cased cartridge with comparable ballistic performance.

Paragraph (a)(6) covers ammunition with pyrotechnic material in the projectile base (22 CFR 121.1). It also covers any ammunition whose projectile carries tracer material with peak radiance above 710 nm, designed to be observed primarily with night vision optical systems. Paragraph (a)(7) covers ammunition that fires superposed or stacked projectiles, for fully automatic firearms or for guns. Paragraph (a)(8) covers electromagnetic armament projectiles or billets for weapons with a design muzzle energy exceeding 5 MJ. Paragraph (a)(9) sweeps in any other ammunition for the guns and armament in Category II.

3. Developmental ammunition

Paragraph (a)(10), which has no asterisk, covers developmental ammunition funded by the Department of Defense and its specially designed parts and components (22 CFR 121.1). It does not control ammunition in production, ammunition placed under the Export Administration Regulations (EAR) by a commodity jurisdiction determination, or ammunition identified in the funding document as developed for both civil and military use. Articles listed elsewhere on the list are not released by those exclusions. Only funding documents dated on or after January 23, 2021 are affected.

4. Handling equipment and parts

Paragraph (b) covers ammunition and ordnance handling equipment specially designed for articles in the category (22 CFR 121.1). It is limited to belting, linking and de-linking equipment and to fuze setting devices. Paragraph (c) is reserved. Paragraph (d) then lists fifteen groups of parts and components.

Several entries describe projectiles (22 CFR 121.1). Paragraph (d)(1) covers projectiles using pyrotechnic tracer materials with peak radiance above 710 nm, and incendiary or explosive projectiles. Explosive projectiles specially designed to scare birds or other pests, such as bird bombs, whistlers and crackers, are excluded from the shotgun entry. Projectiles of any caliber made from depleted uranium are covered. So are projectiles with tips or cores of tungsten, steel or beryllium copper alloy, regardless of caliber, with the M855A1 Enhanced Performance Round as the example. Steel or tungsten shotgun pellets of 0.230 in diameter or less are excluded.

For the Category II guns, paragraph (d) reaches other projectiles, guided or unguided, and their fuzes, rotating bands, cases, liners, fins and boosters (22 CFR 121.1). It also reaches canisters and sub-munitions such as bomblets or minelets, and specially designed cartridge cases, powder bags and combustible cases. Other entries cover non-metallic cases for the paragraph (a)(5) ammunition, and cartridge links and belts for the fully automatic firearms and guns in Categories I and II. Primers other than Boxer, Berdan or shotshell types are covered, but caps and primers of any type in use before 1890 are not.

The remaining entries cover safing, arming and fuzing components, including target detection and proximity sensing devices, and guidance and control components (22 CFR 121.1). Terminal seeker assemblies for ammunition in the category are covered too, as are illuminating flares and target practice projectiles for the paragraph (a)(9) ammunition. The last entry, with an asterisk, catches anything that is classified, contains classified software or is being developed using classified information.

Several of these entries tie back to Category II (22 CFR 121.1). Projectiles, canisters, cases and powder bags are caught only where they are for the guns and armament of that category, and illuminating flares and target practice projectiles only for the paragraph (a)(9) ammunition. Other entries apply whatever the caliber, such as the linked or belted rounds of paragraph (a)(2) and the depleted uranium projectiles and tungsten, steel or beryllium copper tipped or cored projectiles of paragraph (d). No entry in Category III carries the (MT) annotation.

5. What the category leaves out

Three notes at the end of the category mark its outer edge (22 CFR 121.1). The category does not control ammunition crimped without a projectile, known as blank star, or dummy ammunition with a pierced powder chamber. It does not control cartridge and shell casings made useless beyond restoration before export, by heating, flame treatment, mangling, crushing, cutting or popping. Grenades containing non-lethal or less lethal projectiles are under the jurisdiction of the Commerce Department.

6. Technical data and the EAR paragraph

Paragraph (e) brings in the technical data and defense services tied to paragraphs (a), (b) and (d) (22 CFR 121.1). It also controls classified technical data about items in Export Control Classification Numbers 0A505, 0B505, 0D505 and 0E505, and defense services using that data. Paragraphs (f) to (w) are reserved. Paragraph (x) handles Commerce-controlled items sold with the ammunition.

Key terms

Caseless ammunition	Ammunition without a cartridge case holding the primer, propellant and projectile together as a unit.
Superposed or stacked projectiles	The projectile arrangement that brings ammunition for guns and fully automatic firearms into paragraph (a)(7).
Peak radiance above 710 nm	The tracer threshold aimed at rounds observed with night vision systems.
Blank star	Ammunition crimped without a projectile, which the category does not control.
Developmental ammunition	Ammunition funded by the Defense Department and not yet in production.

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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