On July 23, 2026, the U.S. Department of State and the U.S. Department of Commerce published complementary Interim Final Rules that significantly change the export controls applicable to certain firearm suppressors, also referred to as silencers or mufflers.
Effective November 20, 2026, many suppressors currently controlled under the International Traffic in Arms Regulations will instead be controlled under the Export Administration Regulations. The changes are intended to reduce regulatory burdens while maintaining export controls through the Commerce Control List.
What Is Changing?
Certain Suppressors Move From ITAR to the EAR
The Department of State is removing suppressors for non-automatic and semi-automatic firearms from USML Category I. These items will instead be controlled by the Department of Commerce under the EAR.
BIS is adding these items to the Commerce Control List under:
- ECCN 0A501.f
- ECCN 0A502.f
Associated software and technology will also be controlled under the EAR.
Some Suppressors Remain ITAR-Controlled
The rule does not remove all suppressors from the USML.
Suppressors specially designed for fully automatic firearms or fully automatic shotguns will remain subject to the ITAR and continue to require DDTC licensing.
Additional BIS Changes
The BIS rule also makes two notable changes unrelated to the jurisdiction transfer.
License Exception TMP Expanded
License Exception TMP has been expanded to authorize certain temporary exports and reexports of firearms and related items used as tools of trade, reducing the need to obtain individual BIS licenses in qualifying situations.
Temporary Import Clarification
BIS also clarified the EAR’s entry clearance requirements for temporary imports, specifying which EAR-controlled firearms and related items qualify for temporary importation prior to subsequent export.
Effective Dates
| Date | Action |
|---|---|
| July 23, 2026 | Interim Final Rules published; certain conforming regulatory amendments become effective. |
| August 24, 2026 | Deadline to submit public comments on both Interim Final Rules. |
| November 20, 2026 | Jurisdictional transfer of qualifying suppressors from the ITAR to the EAR becomes effective. |
Practical Impact for Exporters
Companies involved in the manufacture, export, brokerage, or distribution of firearm suppressors should begin preparing now by:
- Reviewing product classifications to determine whether affected suppressors will transition from the USML to the CCL.
- Updating internal export classification databases and compliance procedures.
- Reviewing licensing requirements under the EAR, including available license exceptions.
- Training export compliance personnel on the new jurisdiction and licensing requirements.
- Identifying current or future exports that may benefit from the reduced regulatory burden once the rules become effective.
While these changes reduce regulatory requirements for many commercial suppressors, they do not eliminate export controls. Instead, jurisdiction shifts from DDTC to BIS. Exporters should carefully review product classifications, licensing requirements, and applicable EAR controls before relying on the new rules.
Businesses with mixed product lines should also distinguish between suppressors that remain ITAR-controlled and those that will now fall under the EAR.
If your company manufactures, exports, or distributes firearm suppressors or related components, TLR’s Compliance Team at compliance@shiptlr.com can assist with product classification reviews, licensing determinations, compliance program updates, and export procedures ahead of the November 20, 2026 effective date.
