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ITAR · USML22 CFR 121.1, Category XV(a)

Spacecraft and related articles — USML Category XV

Controls satellites and space vehicles that perform named sensing, intelligence or weapons functions, whatever the stated commercial or scientific purpose.

The entry, quoted as it reads today

(a) Spacecraft, including satellites and space vehicles, whether designated developmental, experimental, research, or scientific, or having a commercial, civil, or military end-use, that: * (1) Are specially designed to mitigate effects (e.g., scintillation) of or for detection of a nuclear detonation; * (2) Autonomously detect and track moving ground, airborne, missile, or space objects other than celestial bodies, in real-time using imaging, infrared, radar, or laser systems; * (3) Conduct signals intelligence (SIGINT) or measurement and signatures intelligence (MASINT); * (4) Are specially designed to be used in a constellation or formation that when operated together, in essence or effect, form a virtual satellite (e.g., functioning as if one satellite) with the characteristics or functions of other items in paragraph (a); * (5) Are anti-satellite or anti-spacecraft (e.g., kinetic, RF, laser, charged particle); * (6) Have space-to-ground weapons systems (e.g., kinetic or directed energy); * (7) Have any of the following electro-optical remote sensing capabilities or characteristics:
22 CFR 121.1, Category XV(a) · retrieved 2026-08-29

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

In plain language

Category XV(a) opens with a broad subject and then narrows by function. It covers spacecraft, satellites and space vehicles designated developmental, experimental, research or scientific, and with commercial, civil or military end use. The label on the mission does not settle the outcome; the enumerated capability does.

The controlled functions are specific. They include real-time autonomous tracking of moving ground, airborne, missile or space objects, and signals intelligence. Anti-satellite systems, space-to-ground weapons and nuclear detonation detection are also enumerated.

Paragraph (a)(4) closes a gap for distributed architectures. A constellation or formation specially designed to operate as a virtual satellite is treated by the functions the whole exhibits. Paragraph (a)(7) then continues into named electro-optical remote sensing capabilities.

The questions this entry turns on

  1. 01Does the spacecraft autonomously detect and track moving ground, airborne, missile or space objects in real time?
  2. 02Does the spacecraft conduct signals intelligence or measurement and signatures intelligence?
  3. 03Is the spacecraft specially designed to detect, or to mitigate the effects of, a nuclear detonation?
  4. 04Is the spacecraft specially designed to work in a constellation that in effect forms a virtual satellite with those functions?
  5. 05Does the payload have any of the electro-optical remote sensing capabilities listed at paragraph (a)(7)?
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What typically falls in, and what typically falls out

Typically in

  • A smallsat carrying an imager that autonomously tracks moving vehicles in real time, typically caught by paragraph (a)(2)
  • A cubesat built to collect and geolocate radio-frequency emitters, which typically reads as SIGINT under (a)(3)
  • A formation of satellites specially designed to operate as a single virtual sensor with those functions, typically caught by (a)(4)

Typically out

  • A 3U cubesat carrying a store-and-forward IoT relay radio, typically outside the enumerated functions
  • A university earth science satellite with a wide-field visible camera and no tracking function
  • A drag sail deorbit demonstrator, typically a subsystem demonstration rather than an enumerated capability

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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