USML Category VII: ground vehicles

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1. What counts as a ground vehicle

Category VII of the United States Munitions List (USML) under the International Traffic in Arms Regulations (ITAR) is headed "Ground Vehicles" (22 CFR 121.1). A note makes the term broad. A ground vehicle is any vehicle meeting the control parameters, whatever surface it is designed for, whether highway, off-road, amphibious or rail. It does not matter whether it is controlled manually, remotely or autonomously, or whether it moves on wheels, tracks or legs.

Paragraph (a), marked with an asterisk, covers armored combat ground vehicles, meaning tanks and infantry fighting vehicles (22 CFR 121.1). The asterisk makes them Significant Military Equipment (22 CFR 120.10).

2. Armed vehicles and mission systems

Paragraph (b), also with an asterisk, covers other ground vehicles and trailers that are armed. It also covers those specially designed as a firing or launch platform to deliver munitions or otherwise destroy or incapacitate targets (22 CFR 121.1). The examples are firing lasers, launching rockets, firing missiles, mortars or artillery rounds, and firing other ammunition greater than .50 caliber. Paragraph (c) covers ground vehicles and trailers equipped with any mission systems controlled under the ITAR. Mission systems here again means defense article systems with specific military functions, the note listing communication, target designation, surveillance, target detection and sensors.

Both paragraphs carry the (MT) annotation for vehicles specially designed for certain delivery systems. These are rockets, space launch vehicles, missiles, drones or unmanned aerial vehicles able to deliver a payload of at least 500 kg to a range of at least 300 km (22 CFR 121.1). It flags items on the annex of the Missile Technology Control Regime (22 CFR 120.10). Guns carried on a vehicle are placed by the carrier rule described in Category II, guns and armament.

3. Armored support vehicles

Paragraph (e), with an asterisk, covers armored support vehicles capable of off-road or amphibious use (22 CFR 121.1). They must be specially designed to transport or deploy personnel or materiel, or to move with other vehicles over land in close support of combat vehicles or troops. The examples are personnel carriers, resupply vehicles, combat engineer vehicles, recovery vehicles, reconnaissance vehicles, bridge launching vehicles, ambulances, and command and control vehicles. Paragraphs (d) and (f) are reserved.

A note defines armored ground vehicles in two ways (22 CFR 121.1). They are vehicles with integrated, fully armored hulls or cabs, or vehicles with add-on armor installed to provide ballistic protection to level III of National Institute of Justice Standard 0108.01, September 1985, or better. Armored support vehicles do not include those merely capable of being fitted with add-on armor.

4. Armored civilian vehicles and the Commerce list

A further note draws the line with the Commerce Department’s list (22 CFR 121.1). Military ground vehicles the category does not identify go instead to the Export Administration Regulations (EAR), classified under Export Control Classification Number (ECCN) 0A606. So are unarmed ground vehicles of any origin manufactured before 1956 and unmodified since 1955. ECCN 0A606 also includes unarmed vehicles derived from otherwise EAR99 civilian vehicles and fitted with ballistic protection to level III or better, provided they do not have reactive or electromagnetic armor.

For the pre-1956 rule, changes made for legally required safety features, cosmetic changes such as different paint or repositioned bolt holes, and parts available before 1956 do not count as modifications (22 CFR 121.1). The Commerce Department regulates the export of items on its control list (22 CFR 120.5).

5. Parts, armor and equipment

Paragraph (g) lists fourteen groups of parts, components and systems (22 CFR 121.1). They begin with armored hulls, armored turrets and turret rings, and active protection systems that detect and track incoming threats and launch a countermeasure before contact with the vehicle. Composite, spaced and slat, reactive and electromagnetic armor parts follow, with the interpretations of those terms placed in Category XIII.

Built in test equipment for evaluating the condition of weapons or mission systems is covered (22 CFR 121.1). Equipment that only diagnoses a subsystem involved in the vehicle’s basic operation is excluded. Gun mount, stabilization, turret drive and automatic elevating systems are covered, and so are self-launching bridge components rated class 60 or above. Two suspension parts are named: rotary shock absorbers for vehicles over 30 tons and torsion bars for vehicles over 50 tons, where specially designed for vehicles in the category.

Kits specially designed to convert a Category VII vehicle into an unmanned or driver-optional vehicle are covered (22 CFR 121.1). To be caught, a kit must at least include equipment for remote or autonomous steering, for acceleration and braking, and a control system. Fire control, mission and vehicle management computers, stores management systems and vehicle-weapon interface units are covered, as is test or calibration equipment for the vehicles’ mission systems. Anything classified, carrying classified software tied to defense articles or 600 series items or developed with classified information falls in the asterisked closing entry.

A note sends other specially designed parts and systems not listed in paragraph (g) to ECCN 0A606 (22 CFR 121.1).

6. Technical data and the EAR paragraph

For the vehicles and parts in paragraphs (a) to (g), paragraph (h) picks up the related technical data and defense services (22 CFR 121.1). It also controls classified technical data about items in ECCNs 0A606, 0B606, 0C606 and 0D606, and defense services using that data. Paragraphs (i) to (w) are reserved. Paragraph (x) covers Commerce-controlled items bought with the vehicles.

Two of the category’s entries carry the (MT) annotation, the armed vehicle and mission system paragraphs, each for vehicles specially designed for long-range delivery systems (22 CFR 121.1). The classified parts entry and the technical data paragraph carry the annotation for any articles designated as such.

Key terms

Armored ground vehicle	A vehicle with an integrated armored hull or cab, or add-on armor to level III or better.
Armored support vehicle	An armored off-road or amphibious vehicle designed to carry troops or materiel or support combat vehicles.
Mission systems	Defense article systems providing functions such as military communication, targeting or surveillance.
ECCN 0A606	The Commerce entry for military vehicles not listed in Category VII, and for armored unarmed civilian vehicles.
Driver-optional kit	A conversion kit with steering, acceleration and braking equipment and a control system.

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.

How Sentfore supports this

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