Are AI model outputs considered ITAR or EAR controlled technical data?
It depends on the content and the model's purpose: outputs directly tied to USML defense articles can be ITAR technical data, while dual-use outputs may fall under the EAR (EAR99 or a CCL classification), and much general output is uncontrolled —…
Answer.
It depends on the content and the model's purpose: outputs directly tied to USML defense articles can be ITAR technical data, while dual-use outputs may fall under the EAR (EAR99 or a CCL classification), and much general output is uncontrolled — classification is fact-specific. Recent AI-diffusion rules also reach certain model weights and compute. Planisphere does not classify your data under ITAR/EAR; it keeps the audit in-boundary so you can run it without an unintended export, and the legal classification stays with your export-control counsel.
The mark behind the answer.
USML technical-data control · deemed-export boundary for model artifacts.
More on ITAR.
Prepare evidence for ITAR review.
First evidence record within 21 days of access · re-runs in a single business day. Planisphere measures model behaviour and emits a reproducible, sha-pinned record — it does not certify, file, or give legal advice.