A question people ask · answered against the Corpus of 2026-08-29
Is a thermal camera ITAR?
Usually not. Most commercial thermal cameras are EAR, on 6A003 or 6A002.
The reflex answer in a hardware team is that thermal means ITAR. It is wrong more often than it is right. Uncooled microbolometer cameras sold for inspection, firefighting, building survey and machine vision are almost always Commerce-controlled, not State-controlled.
USML Category XII(c) reaches infrared imaging that was specially designed for a military end use, or that carries military-grade performance. A camera designed and sold for industrial work does not enter Category XII merely because it sees heat.
The Commerce side is where the real threshold lives. 6A002 controls infrared focal plane arrays and imaging equipment by detector type, pitch and frame rate. 6A003 controls the camera systems around them. Above the parameter, a licence may be required for many destinations; below it, the camera can fall to 6A993 or lower.
So the question is never whether the camera is thermal. It is which detector is inside it, at what pitch, at what frame rate, and whether anything in its design traces to a military requirement.
What decides it
- 01Is the detector cooled or uncooled, and what is its pixel pitch in micrometres?
- 02What is the maximum frame rate the camera can output, unrestricted?
- 03Was any part of it specially designed for a military end item, under 22 CFR 120.41?
- 04Is it sold to defence customers, or only to industrial and commercial ones?
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The entries this turns on, opening text as it reads today
a. Optical detectors as follows: a.1. “Space-qualified” solid-state detectors as follows: Note: For the purposes of 6A002.a.1, solid-state detectors include “focal plane arrays”. a.1.a. “Space-qualified” solid-state detectors having all of the following: a.1.a.1. A peak response in the wavelength range exceeding 10 nm but not exceeding 300 nm; and a.1.a.2. A response of less than 0.1% relative to the peak response at a wavelength exceeding 400 nm; a.1.b. “Space-qualified” solid-state detectors having all of the following: a.1.b.1. A peak response in the wavelength range exceeding 900 nm but not exceeding 1,200 nm; and a.1.b.2. A response “time constant” of 95 ns or less; a.1.c. “Space-qualified” solid-state detectors having a peak response in the wavelength range exceeding 1,200 nm but not exceeding 30,000 nm; a.1.d […]
a. Instrumentation cameras and “specially designed” “components” therefor, as follows: Note: Instrumentation cameras, controlled by 6A003.a.3 to 6A003.a.5, with modular structures should be evaluated by their maximum capability, using plug-ins available according to the camera manufacturer's specifications. a.1. [Reserved] a.2. [Reserved] a.3. Electronic streak cameras having temporal resolution better than 50 ns; a.4. Electronic framing cameras having a speed exceeding 1,000,000 frames/s; a.5. Electronic cameras having all of the following: a.5.a. An electronic shutter speed (gating capability) of less than 1µs per full frame; and a.5.b. A read out time allowing a framing rate of more than 125 full frames per second; a.6. Plug-ins having all of the following characteristics: a.6.a […]
* (c) Imaging systems or end items, as follows: (1) Binoculars, bioculars, monoculars, goggles, or head or helmet-mounted imaging systems (including video-based articles having a separate near-to-eye display), as follows: (i) Employing an autogated third generation image intensifier tube or a higher generation image intensifier tube; (ii) Fusing output of an image intensifier tube and an infrared focal plane array having a peak response wavelength greater than 1,000 nm; or (iii) Having an infrared focal plane array or infrared imaging camera, and specially designed for a military end user; (2) Weapon sights ( i.e., with a reticle) or aiming or imaging systems (e.g., clip-on), specially designed to mount to a weapon or to withstand weapon shock or recoil, with or without an integrated viewer or display, and also incorporating or specially designed to incorporate any of the following: […]
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
- Is a night vision scope ITAR?Often yes. Image-intensifier night vision is the part of optics that sits squarely in USML Category XII.
- 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.