On August 27, 2025, the Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR”) and updating the U.S. Munitions List (“USML”). The rule, effective September 15, 2025, implements changes following public comment and periodic review required under the Arms Export Control Act.

The latest ITAR amendments remove certain items from control, including lead-free birdshot ammunition and GNSS anti-jam/anti-spoofing systems, based on assessments that these no longer provide a critical military or intelligence advantage. At the same time, new controls have been added for advanced aircraft parts and large unmanned underwater vehicles (“UUVs”) with specific military features, reflecting ongoing technology developments and national security priorities. The Department also clarified definitions for terms such as “foreign advanced military aircraft” and “mission systems,” and added the F-47 fighter to the USML. These revisions respond directly to industry feedback and public comments, with refinements to controls for aircraft radar, IEDs, body armor, antennas, and other entries.

A significant feature of the rule is a new exemption in ITAR §126.9(u), which allows for the temporary export, reexport, and import of certain large UUVs (under 8,000 lbs.) for scientific research, civil infrastructure, or search and rescue purposes, provided there is no transfer of registration, control, or ownership to a foreign person. This exemption is intended to facilitate legitimate civilian and research uses of advanced underwater technology while maintaining strict controls against diversion to military applications.

For items removed from the USML, exporters must now review jurisdiction and licensing procedures under the Export Administration Regulations (“EAR”). Existing DDTC licenses for transitioning items will remain valid for up to three years to allow industry time to adjust to the new regulatory environment.

These targeted revisions are part of the Department’s ongoing effort to keep ITAR focused on items that provide a critical military or intelligence advantage and to ensure the USML reflects technological and commercial realities. Exporters, manufacturers, and research institutions should review the revised USML and ITAR provisions to ensure compliance.

Crowell will continue to monitor developments in U.S. export controls and their impact on industry.

Tags: EAR, ITAR, USML
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Photo of Scott Wise Scott Wise

Scott Wise is a partner in Crowell’s Denver office and a member of the firm’s International Trade Group. His practice focuses on export controls, economic sanctions, and outbound investment issues across industries, with an emphasis on emerging technologies and the technology industry.

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Scott Wise is a partner in Crowell’s Denver office and a member of the firm’s International Trade Group. His practice focuses on export controls, economic sanctions, and outbound investment issues across industries, with an emphasis on emerging technologies and the technology industry.

Working with established and start-up tech companies, Scott helps clients to develop unique compliance programs that are responsive to the full range of regulations governing the exports of goods and services. He also trains and counsels clients on compliance with relevant export control regulations such as the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). In addition to technology companies, Scott advises companies in the aerospace and aviation, automotive, chemical, defense, electronics, energy, engineering, financial and insurance, manufacturing, professional services, security, and transportation industries, among others.

Prior to joining Crowell, Scott was the Assistant General Counsel for Global Trade at a multinational technology company where he led a consolidated team focusing on export controls, economic sanctions, and outbound investment. He was the lead export controls and economic sanctions attorney for key business groups ranging from emerging technologies, such as artificial intelligence and quantum computing, to aerospace and defense contracts, and to commercial software and gaming. In that role, Scott developed the company’s compliance approach to new regulations governing the export of various  new technologies, including AI, integrated circuits and chips, and quantum computing, which involved coordination between senior government officials and business leaders. Scott also has prior law firm experience in the international trade practice area.

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Photo of Chandler Leonard Chandler Leonard

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce…

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.

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Photo of Andrew J. Schlegel Andrew J. Schlegel

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

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Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.

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