A question people ask · answered against the Corpus of 2026-08-29
Is a telemetry radio export controlled?
Usually yes, in the light sense: 3A991 or 5A002 rather than the USML.
A telemetry or control radio is rarely a munitions item. USML Category XI(a) reaches electronic equipment specially designed for military use — jammers, military datalinks, electronic warfare gear. A commercial 900 MHz or 2.4 GHz link is not that.
On the Commerce side there are 2 entries to walk. 3A991 covers general-purpose electronic components and assemblies below the higher Category 3 thresholds. 5A002 catches the radio if the link is encrypted above the cryptographic thresholds, which most modern links are.
Frequency-hopping and spread-spectrum by themselves are not controls. What matters is the cryptography, the output power, and whether anything about the design traces to a military requirement.
A radio can be EAR99 as hardware and still be caught by 5A002 because of the firmware inside it. The classification follows the product as shipped, not the bill of materials.
What decides it
- 01Is the link encrypted, and with what algorithm and key length?
- 02What is the RF output power, and is it user-adjustable?
- 03Was the radio specially designed for a military platform or datalink?
- 04Does it implement frequency hopping under a military waveform standard?
Free, no account. Dossier $249 if you want the record.
The entries this turns on, opening text as it reads today
a. “Microprocessor microcircuits”, “microcomputer microcircuits”, and microcontroller microcircuits having any of the following: a.1. A performance speed of 5 GFLOPS or more and an arithmetic logic unit with an access width of 32 bit or more; a.2. A clock frequency rate exceeding 25 MHz; or a.3. More than one data or instruction bus or serial communication port that provides a direct external interconnection between parallel “microprocessor microcircuits” with a transfer rate of 2.5 Mbyte/s; b. Storage integrated circuits, as follows: b.1. Electrical erasable programmable read-only memories (EEPROMs) with a storage capacity; b.1.a. Exceeding 16 Mbits per package for flash memory types; or b.1.b. Exceeding either of the following limits for all other EEPROM types: b.1.b.1. Exceeding 1 Mbit per package; or b.1.b.2 […]
a. Designed or modified to use 'cryptography for data confidentiality' having a 'described security algorithm', where that cryptographic capability is usable, has been activated, or can be activated by any means other than secure “cryptographic activation”, as follows: a.1. Items having “information security” as a primary function; a.2. Digital communication or networking systems, equipment or components, not specified in paragraph 5A002.a.1; a.3. Computers, other items having information storage or processing as a primary function, and components therefor, not specified in paragraphs 5A002.a.1 or .a.2; N.B. : For operating systems see also 5D002.a.1 and .c.1. a.4. Items, not specified in paragraphs 5A002.a.1 to a.3, where the 'cryptography for data confidentiality' having a 'described security algorithm' meets all of the following: a.4.a. It supports a non-primary function of the item; […]
(a) Electronic equipment and systems not included in Category XII of the U.S. Munitions List, as follows: * (1) Underwater hardware, equipment, or systems, as follows: (i) Active or passive acoustic array sensing systems or acoustic array equipment capable of real-time processing that survey or detect, and also track, localize ( i.e., determine range and bearing), classify, or identify, surface vessels, submarines, other undersea vehicles, torpedoes, or mines, having any of the following: (A) Multi-static capability; (B) Operating frequency less than 20 kHz; or (C) Operating bandwidth greater than 10 kHz; (ii) Underwater single acoustic sensor system that distinguishes non-biologic tonals and locates the origin of the sound; Note to paragraph( a )(1)( ii ): The term tonals implies discrete frequencies in the broadband and narrowband spectra, emanating from man-made objects. […]
Skenai never shows unquoted regulation. This page is research and documentation, not legal advice, and it is not a determination on your product.
People who ask this also ask
- Does encryption in my product need an export licence?Encryption puts you on 5A002 by default, but most commercial products move under a licence exception with a filing.
- Is an FPV drone ITAR?Rarely. Most civilian FPV and industrial drones are EAR, and 9A012 is the entry to check first.
- What does EAR99 mean?It means the item is subject to the EAR but is not listed on the Commerce Control List. It is a residual, not a clearance.
A general answer is not your answer.
The Interview asks 5 to 9 questions about your product, only the ones the entries turn on, and names the Determination free. The Dossier is the dated, cited record of how it was reached — the thing an investor or a prime asked for.
Free, no account. Dossier $249 if you want the record.