US amends ITAR, US Munitions List, and Major Non-NATO Allies List

22 September 2026

US amends ITAR, US Munitions List, and Major Non-NATO Allies Listsharpner/Shutterstock.com

The US Department of State has amended the  International Traffic in Arms Regulations (ITAR), removing from the US Munitions List  (USML) certain uncrewed underwater vehicles,  updating country policies of denial, and updating the Major Non-NATO Allies List (MNNA). See our US Export Controls and Legislation page for more information on ITAR and these lists.

USML Amendments

Category XX(a)(10) covers uncrewed, untethered vessels. As a result of the amendments:

  • Vessels 3,000 - 8,000 lb are only listed on the USML if they have navigation capabilities that go beyond fixed waypoints, station-keeping and see-and-avoid collision avoidance.
  • Vessels over 8,000 lb are listed on the USML if they can operate without human interaction for more than 24 hours or 70 nautical miles, and now fall under Category XX(a)(11).

The amendments will come into effect on 19 October 2026. The Department has requested comments from the public on the amendment, and in answer to the questions listed on the notice.

ITAR Amendments

ITAR § 126.1’s “policy of denial” lists the states with which the US generally prohibits defence exports and imports. The amendments clarify that the prohibition also covers reexports, retransfers and temporary imports of defence articles and services to or from listed states. The amendments also remove Ethiopia from the list, and application for licenses to export to Ethiopia will now be processed on a case-by-case basis.

ITAR’s § 120.23 lists the US’ major non-NATO allies on the MNNA List. The states are designated by the President to facilitate defence and security co-operation. Saudi Arabia and Peru have been added to the MNNA list.

These amendments came into effect on 18 September 2026 with no comment period.

Maya Lester KC

Maya Lester KC is a senior barrister (King’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. She is the…

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