In Force Checked October 24, 2026
On October 1, 2026, DDTC proposed omnibus amendments that would move some items off the US Munitions List and add exemptions; comments are due November 30, 2026, and the current text applies until a final rule.
Next: Watch for the final omnibus rule, and review any items you classify under USML Categories II, VIII, X or XX.
What It Covers
Control of the export and temporary import of defense articles and services on the US Munitions List, including the technical data that describes them.
Who It Applies To
Manufacturers, exporters and brokers of defense articles, and anyone who handles ITAR-controlled technical data, including the people inside your own building.
Key Requirements
- Registration with DDTC for manufacturers and exporters of defense articles (Part 122).
- A license or exemption before exporting defense articles or technical data, including release to foreign persons in the United States (a deemed export).
- Jurisdiction and classification against the US Munitions List (Part 121).
- Records kept for five years, and voluntary disclosure of violations (Parts 122, 127).
What an Auditor Asks to See
- How controlled drawings are marked, stored, and released.
- Your list of foreign-person employees and visitors, and the access controls that apply to them.
Where Systems Fall Short
- Controlled drawings shared by email with suppliers who were never screened.
- Quality records that include technical data but sit outside the export control plan.
How QES Helps
Document control set up so that export-controlled data is identified, marked, and released only to people entitled to it.
Related Standards
Sources. eCFR — 22 CFR Chapter I, Subchapter M (ITAR) (opens in a new tab); Holland & Knight — DDTC publishes ITAR omnibus amendments proposed rule (October 2026) (opens in a new tab). Status checked October 24, 2026. This page summarizes ITAR · 22 CFR 120–130; it does not reproduce or replace it. Buy the standard from its publisher, or read the regulation in its official text, before relying on a detail. Not legal advice.