A question people ask · answered against the Corpus of 2026-08-29
Is an FPV drone ITAR?
Rarely. Most civilian FPV and industrial drones are EAR, and 9A012 is the entry to check first.
An FPV airframe that a hobbyist could build is not on the US Munitions List because it flies. USML Category VIII(a) reaches aircraft specially designed for a military end use — armed, hardened, or built to a military specification.
The Commerce Control List is the live question. ECCN 9A012 controls unmanned aerial vehicles designed to fly beyond the operator's direct natural vision, and it sorts them by endurance and by wind-gust capability. Thirty minutes of endurance is a threshold that a great many 7-inch and 10-inch builds cross.
The payload is a separate analysis from the airframe. A drone can sit at EAR99 while the thermal camera bolted to it sits on 6A003, and the shipment is controlled by the more restrictive part.
Where teams get caught is end use. Selling the same airframe to a defence integrator, or marketing it for target acquisition, can move the design intent and with it the jurisdiction.
What decides it
- 01What is the maximum endurance in a single flight, with the standard battery?
- 02Is it designed for controlled flight in wind gusts at or above 46.3 km/h?
- 03Is it marketed, sold or configured for any military or law-enforcement use?
- 04What is on the payload rail — camera, radio, or nothing?
Free, no account. Dossier $249 if you want the record.
The entries this turns on, opening text as it reads today
a. “UAVs” or unmanned “airships”, designed to have controlled flight out of the direct 'natural vision' of the 'operator' and having any of the following: a.1. Having all of the following: a.1.a. A maximum 'endurance' greater than or equal to 30 minutes but less than 1 hour; and a.1.b. Designed to take-off and have stable controlled flight in wind gusts equal to or exceeding 46.3 km/h (25 knots); or a.2. A maximum 'endurance' of 1 hour or greater; Technical Notes: 1. For the purposes of 9A012.a, 'operator' is a person who initiates or commands the “UAV” or unmanned “airship” flight. 2. For the purposes of 9A012.a, 'endurance' is to be calculated for ISA conditions (ISO 2533:1975) at sea level in zero wind.3. For the purposes of 9A012.a, 'natural vision' means unaided human sight, with or without corrective lenses. b. Related equipment and “components”, as follows: b.1 [Reserved] b.2 […]
(a) Aircraft, whether manned, unmanned, remotely piloted, or optionally piloted, as follows (MT if the aircraft, excluding manned aircraft, has a range equal to or greater than 300 km): * (1) Bombers; * (2) Fighters, fighter bombers, and fixed-wing attack aircraft; * (3) Turbofan- or turbojet-powered trainers used to train pilots for fighter, attack, or bomber aircraft; * (4) Attack helicopters; * (5) Unmanned aerial vehicles (UAVs) specially designed to incorporate a defense article; * (6) [Reserved] * (7) Aircraft specially designed to incorporate a defense article for the purpose of performing an intelligence, surveillance, and reconnaissance function; […]
§ 120.41 Specially designed. (a) Except for commodities or software described in paragraph (b) of this section, a commodity or software is specially designed if it: (1) As a result of development, has properties peculiarly responsible for achieving or exceeding the controlled performance levels, characteristics, or functions described in the relevant U.S. Munitions List (USML) paragraph in § 121.1 of this subchapter; or Note 1 to paragraph (a)(1): An example of a commodity that as a result of development has properties peculiarly responsible for achieving or exceeding the controlled performance levels, functions, or characteristics in a USML category would be a swimmer delivery vehicle specially designed to dock with a submarine to provide submerged transport for swimmers or divers from submarines. […]
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 my drone need an export licence?It depends on the ECCN and the destination country, not on the drone alone.
- Is a thermal camera ITAR?Usually not. Most commercial thermal cameras are EAR, on 6A003 or 6A002.
- Is a drone motor or ESC ITAR?Almost never on its own. A commercial motor sold into both markets is released by the specially designed test.
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.