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ITAR · USML22 CFR 121.1, Category VIII(a)

Aircraft and related articles — USML Category VIII

Controls military aircraft of every crewing arrangement, including unmanned aircraft specially designed to carry a defense article.

The entry, quoted as it reads today

(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; * (8) Aircraft specially designed to incorporate a defense article for the purpose of performing an electronic warfare function; airborne warning and control aircraft; or aircraft specially designed to incorporate a defense article for the purpose of performing a command, control, and communications function; (9) Aircraft specially designed to incorporate a defense article for the purpose of performing an air refueling function; (10) Target drones; (11) [Reserved] (12) Aircraft capable of being refueled in-flight including hover-in-flight refueling (HIFR); (13) [Reserved] (14) Aircraft with a roll-on/roll-off ramp, capable of airlifting payloads over 35,000 lbs. to ranges over 2,000 nm without being refueled in-flight, and landing onto short or unimproved airfields, other than L-100 and LM-100J aircraft; * (15) Aircraft not enumerated in paragraphs (a)(1) through (a)(14) as follows:
22 CFR 121.1, Category VIII(a) · retrieved 2026-08-29

Corpus last verified 2026-08-29. Skenai never shows unquoted regulation.

In plain language

Category VIII(a) covers aircraft whether manned, unmanned, remotely piloted or optionally piloted. The enumerated types include bombers, fighters, attack helicopters, target drones and certain jet trainers. Crewing is not the deciding factor; the mission the airframe was built for is.

Several paragraphs turn on the phrase specially designed to incorporate a defense article. That wording captures unmanned aircraft under (a)(5), and aircraft built to perform intelligence, surveillance and reconnaissance, electronic warfare, or command, control and communications functions. The defense article is the anchor, and the airframe follows it.

The category also reaches capability rather than mission in places. In-flight refuelling capability is enumerated, as is a roll-on ramp airlifter above stated payload and range figures. For unmanned aircraft, a range of 300 km or more adds the missile technology designation.

The questions this entry turns on

  1. 01Is the aircraft an enumerated type, such as a bomber, fighter, attack helicopter or target drone?
  2. 02Is the unmanned aircraft specially designed to incorporate a defense article, per paragraph (a)(5)?
  3. 03Was the aircraft specially designed to incorporate a defense article for an ISR, electronic warfare or C3 function?
  4. 04Is the aircraft capable of being refuelled in flight, including hover-in-flight refuelling?
  5. 05For an unmanned aircraft, is the range equal to or greater than 300 km, which adds the MT designation?
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What typically falls in, and what typically falls out

Typically in

  • A fixed-wing UAV specially designed around a military ISR payload, which typically reads onto paragraph (a)(7)
  • A target drone built for live-fire training, which is typically enumerated at paragraph (a)(10)
  • An optionally piloted aircraft modified to carry an electronic warfare payload, typically caught by paragraph (a)(8)

Typically out

  • A consumer camera quadcopter with no military heritage, which typically sits in the EAR rather than here
  • An agricultural spray drone built to an agronomy specification, typically outside the enumerated types
  • A survey mapping UAV sold to civil engineering firms, which typically moves to ECCN 9A012 instead

These are typical cases, not determinations. Which side a specific product lands on turns on the answers in the Interview.

Adjacent entries

Does your product land on this entry?

The Interview asks 5 to 9 questions, only the ones this entry turns on, and names the Determination free. The Dossier is the dated, cited record of how it was reached.

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