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U.S. State Department revises USML controls for certain uncrewed underwater vehicles

Certain uncrewed underwater and other uncrewed vessels move from ITAR to Export Administration Regulations (EAR) jurisdiction.

September 18, 2026

The U.S. Department of State issued an interim final rule amending the International Traffic in Arms Regulations (ITAR) to remove from the U.S. Munitions List (USML) certain uncrewed underwater vehicles (UUVs) and make related changes to USML Category XX(a).

The rule revises Category XX(a)(10) to cover only uncrewed, untethered vessels with a gross weight rating of more than 3,000 pounds and not more than 8,000 pounds that are specially designed both to operate without human interaction for more than 24 hours or more than 70 nautical miles and to possess specified navigation capabilities beyond following fixed waypoints, station-keeping, or see-and-avoid collision-avoidance maneuvers.

The rule also creates a new Category XX(a)(11) for uncrewed, untethered vessels with a gross weight rating exceeding 8,000 pounds that are specially designed to operate without human interaction for more than 24 hours or more than 70 nautical miles.

The State Department explains that vessels removed from USML control and not otherwise described on the USML will become subject to the Export Administration Regulations (EAR).

The rule is effective October 19, 2026. Notably, the rule requests comments, due October 19, 2026, including any specific comments regarding navigation capabilities of UUVs to assist in further refining ITAR controls on such items or about possible enhancements to the license exemption for certain UUV-related activities.

For more information, contact a professional with KPMG Trade & Customs services:

 

Andrew Siciliano
Partner, U.S. & Global Practice Leader

E: asiciliano@kpmg.com

Doug Zuvich
Partner

E: dzuvich@kpmg.com

Irina Vaysfeld
Principal

E: ivaysfeld@kpmg.com

John L. McLoughlin
Principal

E: jlmcloughlin@kpmg.com

Luis (Lou) Abad
Principal

E: labad@kpmg.com

George Zaharatos
Principal

E: gzaharatos@kpmg.com

Christopher Young
Principal

E: christopheryoung@kpmg.com

Amie Ahanchian
Principal

E: aahanchian@kpmg.com

Gisele Belotto
Principal

E: gbelotto@kpmg.com

Steve Brotherton
Principal

E: sbrotherton@kpmg.com

Jessica Libby
Principal

E: jlibby@kpmg.com

Dawn Olesky
Principal

E: dolesky@kpmg.com

Frances Xing
Principal

E: francesxing@kpmg.com

 

 

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