BIS removes 4 Chinese entities from Unverified List after bona-fide verification

Mechanism

The Unverified List (Supplement No. 6 to 15 CFR Part 744) lists foreign persons whose bona fides BIS has been unable to verify through end-use checks. Placement on the UVL does not constitute a finding of wrongdoing, but it suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting any EAR-subject item. Removal requires BIS to successfully complete an end-use check confirming the entity's legitimacy.

All four removals in this rule took effect 15 December 2023 (the day the document was officially filed with the Office of the Federal Register), four days before the notice's print publication date of 19 December 2023.

The four removed entities:

Context

This action was published on the same day as a companion BIS rule adding 13 entities to the UVL (88 FR 87897, FR Doc 2023-27928), all located in China. The simultaneous additions/removals pattern is typical of routine BIS UVL maintenance cycles.

The Xinjiang-domiciled entity (East Hope New Energy) is notable given the Uyghur Forced Labor Prevention Act (UFLPA) environment: its UVL removal indicates BIS was able to complete a physical end-use check, but it does not constitute a UFLPA clearance or customs-compliance determination.

Downstream implications

• US exporters may resume use of EAR license exceptions (e.g., EAR99 No License Required,

License Exception STA) for shipments to these four parties without a UVL Statement.

• The Erzhong removal is commercially meaningful: China National Erzhong Group is a major

state-owned heavy-equipment manufacturer; UVL placement had constrained US-origin industrial equipment and component flows.

• No impact on the broader export-control perimeter — this is a routine verification

completion, not a policy liberalisation.

Open questions

• Whether the concurrent 13-entity addition rule (2023-12-20-us-bis-uvl-13-additions-china)

reflects continued difficulty verifying Chinese entities in certain sectors (e.g., logistics, electronics) versus the resolved verification cases here.