Skip to main content
v2026.11,610 entries · CC-BY 4.0
Dictionary termTrack DProposedv2026.1

22 CFR Part 120 (ITAR — Purpose and Definitions)

22 CFR Part 120 is the opening part of the International Traffic in Arms Regulations (ITAR), the body of US federal regulations administered by the Department of State's Directorate of Defense Trade Controls (DDTC) that controls the export and temporary import of defense articles and defense services on the US Munitions List (USML). Part 120 does not itself list controlled items -- that is Part 121 (the USML) -- instead it states ITAR's statutory basis and purpose (Subpart A) and, in Subpart C (22 CFR 120.30-120.69), supplies the controlling definitions used throughout the rest of ITAR (22 CFR Parts 121-130), including 'defense article,' 'defense service,' 'technical data,' 'export,' 'US person,' and 'foreign person.' Because these definitions govern how every other ITAR part is read, a research institution's export-control determination for a given item, collaboration, or foreign national almost always traces back to a Part 120 definition rather than to a substantive control provision elsewhere in ITAR.

ByCASRAI Editorial Board
· Last updated 15 Aug 2026

Ask about 22 CFR Part 120 (ITAR — Purpose and Definitions)

Answers are drawn from this dictionary entry and the rest of the CASRAI corpus, with a link to every source.

Answers are AI-generated from CASRAI’s own published pages and can be wrong, so check the linked sources before relying on one; your question is logged without personal data — never sold, never used to train a third-party model — to show us what CASRAI is missing, so please do not type personal or confidential details. How we use this

Examples

Worked examples

  • Is an instance

    A university export control office reviewing whether sharing a device specification with a foreign-national graduate student is a 'deemed export' starts from the Part 120 definitions of 'technical data' and 'foreign person' (22 CFR 120.63), not from a Munitions List category, because whether the disclosure counts as a controlled release at all turns on those two definitions.

  • Is an instance

    Determining whether a visiting researcher on an employment-based visa counts as a 'US person' for ITAR purposes requires applying the Part 120 definition at 22 CFR 120.62, which turns on lawful-permanent-resident or 'protected individual' status under 8 U.S.C. 1101(a)(20) and 8 U.S.C. 1324b(a)(3) -- not on the researcher's institutional appointment or funding source.

Counter-examples

Looks similar, but isn't

  • Not an instance

    The US Munitions List itself -- the categorized list of specific defense articles and defense services that are actually controlled -- is 22 CFR Part 121, not Part 120; Part 120 supplies the definitions Part 121's categories are read against, but contains no controlled-item list itself.

  • Not an instance

    The parallel dual-use regime, the Export Administration Regulations (EAR, 15 CFR Parts 730-774) administered by the Commerce Department's Bureau of Industry and Security, has its own separate definitions section (15 CFR Part 772) -- a term defined in 22 CFR Part 120 does not automatically carry the same meaning under the EAR, even where the same English word is used in both regulations.

Editorial commentary

Research fellow” is one of the least standardized titles in academic research administration — the same two words point to genuinely different positions depending on country, and even depending on institution within the same country. There is no single authoritative definition to give, and treating the title as universal is itself the most common mistake when comparing CVs, job ads, or HR classifications across institutions.

The core split: UK/Commonwealth usage vs. US usage

In the United Kingdom and much of the Commonwealth academic system, “research fellow” typically names a distinct career grade on a research-only pathway that sits above the entry-level postdoctoral stage, not a synonym for it. Universities operating a research career pathway commonly place research associate (the first postdoctoral grade) below research fellow, with senior research fellow and principal research fellow above it — roughly parallel, at each step, to the lecturer – senior lecturer – reader/associate professor teaching-track ladder, though the exact grade-to-grade mapping varies by institution. Vitae, the UK body responsible for the Researcher Development Framework, describes a research fellow appointment as prestigious and competitive, typically requiring at least two years of research experience after the doctorate — already a meaningfully more senior bar than “recently defended.” Employment terms vary by institution and funding source: some research fellow posts are fixed-term (tied to a grant or personal fellowship award), while others are open-ended, subject to normal probation, once an institution has moved someone onto its permanent research-only pathway. Where a career-grade research fellow role does carry duties beyond running their own research, UK sources describe those duties as “a moderate amount of teaching and/or supervision (often at postgraduate level)” — not the standard teaching load of a lecturer, but not none either. This is materially different from a postdoctoral researcher, whose defining features are a fixed, typically one-to-five-year term and an explicit developmental/mentored purpose rather than research autonomy or a leadership role on a project.

In the United States, usage is genuinely inconsistent rather than following one alternate convention. Some institutions use “research fellow” (or “postdoctoral research fellow” / “postdoctoral fellow”) as a direct synonym for a postdoc — particularly where the position is funded by an individual fellowship rather than a PI’s grant, since “fellow” in US usage often signals fellowship-funded/trainee status rather than seniority. Other US institutions reserve “research fellow” (or a parallel research-track ladder such as research assistant professor → research associate professor → research professor) for a more senior, non-tenure-track research faculty rank distinct from and above the postdoc stage, generally not carrying teaching obligations but sometimes carrying grant-holding authority a postdoc lacks. Because both conventions are genuinely in active use, the title alone does not reliably communicate seniority in a US context the way it more often does in the UK — the funding mechanism, appointment letter, and institutional policy are what actually determine status, not the job title.

What to check, in practice

Because “research fellow” is not self-defining, resolving what a specific position actually is requires checking, in order: (1) the institution’s own HR/academic-titles policy or career-pathway document, since many universities publish exactly this kind of grade table; (2) whether the appointment is fixed-term or open-ended, and for how long; (3) the funding source — institutional core funding, a research grant, or a named personal fellowship, since this often determines both employment classification and expected duration; and (4) whether the role includes named teaching, supervision, or grant-holding (principal investigator) authority, which distinguishes a genuinely senior research fellow appointment from an entry-level one using the same title. For cross-institution or cross-border comparison (a common CRIS/HR-integration and research-assessment problem), relying on the literal job title without this check risks miscategorizing career stage entirely — a UK “senior research fellow” and a US “postdoctoral research fellow” can differ by a decade of research seniority despite sharing the word “fellow.”

Examples

  • A UK university appoints a researcher, seven years post-PhD, to an open-ended “Research Fellow” post on its research career pathway, with an expectation of independent grant applications and co-supervision of PhD students — a genuinely senior, non-teaching-track academic role distinct from a postdoc.
  • A US biomedical institute advertises a “Postdoctoral Research Fellow” position funded by an NIH training grant for a recent PhD graduate — functionally identical to what the same institution might otherwise call a “postdoctoral researcher” or “postdoctoral associate,” with the “fellow” language reflecting fellowship/trainee funding status rather than added seniority.

Counter-example: a doctoral candidate who has not yet defended, or a research assistant working toward (rather than holding) a doctorate, is not a research fellow under either convention — both UK and US usage require the doctorate to already be conferred.

Why this matters for research administration

The title’s ambiguity has concrete downstream effects wherever job titles get treated as structured data rather than free text: CRIS/HR system role mappings, cross-institutional researcher-mobility comparisons, funder eligibility criteria that reference career stage (e.g. “within N years of PhD”), and international recruitment where a candidate’s CV title needs translating into a comparable local grade. Systems and policies that key off the literal string “research fellow” without also capturing years-post-PhD, contract type, and funding mechanism will systematically misclassify at least one side of the UK/US divide described above.

Frequently Asked Questions

What is the difference between a research associate and a research fellow?

In UK and Commonwealth academic systems, these are different grades on the same research-only career pathway, not interchangeable titles. Research associate is typically the first postdoctoral grade, while research fellow sits above it and generally requires at least two years of research experience after the doctorate. In the US this distinction is not applied consistently, and some institutions use “research fellow” as a direct synonym for a postdoc instead.

Is a research fellow the same as a postdoc?

It depends on the country. In the UK, a research fellow post is typically a distinct, more senior career grade above the postdoctoral stage, unlike a postdoctoral researcher role, which is defined by a fixed term and a developmental, mentored purpose. In the US, some institutions use “research fellow” as a direct synonym for a postdoc — especially where the position is funded by an individual fellowship rather than a supervisor’s grant — while others reserve it for a more senior, distinct non-tenure-track rank.

Do you need a PhD to become a research fellow?

Yes. Under both UK/Commonwealth and US conventions, the doctorate must already be conferred. A doctoral candidate who has not yet defended, or a research assistant still working toward a doctorate, is not a research fellow under either convention.

Is a research fellow considered a student?

No. “Research fellow” designates someone who already holds a doctorate and is in a research-focused position, not someone still studying for one, regardless of which country’s usage applies.

What is the difference between a research fellow and a senior or principal research fellow?

Senior research fellow and principal research fellow are further grades above research fellow on the same UK/Commonwealth research-only career pathway, roughly parallel to the lecturer – senior lecturer – reader/associate professor ladder used for teaching-track academics. The exact grade-to-grade mapping varies by institution.

Machine-readable encodings

Use in your systems

JATS XML <role> element
xml
<role vocab="credit"
      vocab-identifier="https://casrai.org/dictionary/"
      vocab-term="22 CFR Part 120 (ITAR — Purpose and Definitions)"
      vocab-term-identifier="https://casrai.org/dictionary/term/22-cfr-part-120-itar-purpose-and-definitions" />
Schema.org DefinedTerm (JSON-LD)
json
{
  "@context": "https://schema.org",
  "@type": "DefinedTerm",
  "@id": "https://casrai.org/dictionary/term/22-cfr-part-120-itar-purpose-and-definitions",
  "name": "22 CFR Part 120 (ITAR -- Purpose and Definitions)",
  "identifier": "https://casrai.org/dictionary/term/22-cfr-part-120-itar-purpose-and-definitions",
  "description": "22 CFR Part 120 is the opening part of the International Traffic in Arms Regulations (ITAR), the body of US federal regulations administered by the Department of State's Directorate of Defense Trade Controls (DDTC) that controls the export and temporary import of defense articles and defense services on the US Munitions List (USML). Part 120 does not itself list controlled items -- that is Part 121 (the USML) -- instead it states ITAR's statutory basis and purpose (Subpart A) and, in Subpart C (22 CFR 120.30-120.69), supplies the controlling definitions used throughout the rest of ITAR (22 CFR Parts 121-130), including 'defense article,' 'defense service,' 'technical data,' 'export,' 'US person,' and 'foreign person.' Because these definitions govern how every other ITAR part is read, a research institution's export-control determination for a given item, collaboration, or foreign national almost always traces back to a Part 120 definition rather than to a substantive control provision elsewhere in ITAR.",
  "inDefinedTermSet": "https://casrai.org/dictionary/domain/research-security#set",
  "url": "https://casrai.org/dictionary/term/22-cfr-part-120-itar-purpose-and-definitions",
  "sameAs": [],
  "license": "https://creativecommons.org/licenses/by/4.0/",
  "publisher": {
    "@id": "https://casrai.org/#organization"
  },
  "dateModified": "2026-08-15T04:39:29",
  "inLanguage": "en"
}

Referenced across the research world

University of Cambridge logoColumbia University logoCrossref logoUniversity of Edinburgh logoHarvard University logoUniversity of Oxford logoPrinceton University logoStanford School of Medicine logoUniversity College London logoORCID logoUniversity of Cambridge logoColumbia University logoCrossref logoUniversity of Edinburgh logoHarvard University logoUniversity of Oxford logoPrinceton University logoStanford School of Medicine logoUniversity College London logoORCID logo
  • University of Cambridge logo
  • Columbia University logo
  • Crossref logo
  • University of Edinburgh logo
  • Harvard University logo
  • University of Oxford logo
  • Princeton University logo
  • Stanford School of Medicine logo
  • University College London logo
  • ORCID logo

View CASRAI adoption →