BIS revises License Exception IEC (15 CFR 740.24) — incorporates updated table adding Denmark and Finland and modifying Japan entries

Mechanism

License Exception IEC, codified at 15 CFR § 740.24, was created by BIS's 6 September 2024 final rule (RIN 0694-AJ72, 89 FR 72932) implementing plurilateral controls on advanced semiconductor manufacturing, quantum computing, and additive manufacturing items. The mechanism allows exports, re-exports, and transfers of specified Export Control Classification Number (ECCN) entries to be authorised under licence exception — rather than requiring a BIS export licence — when the destination country has implemented substantially equivalent multilateral export controls of its own. Eligibility is determined by a table that BIS maintains and incorporates by reference into § 740.24(c).

The 16 October 2024 rule does two things: (i) it updates the version date of the incorporated-by-reference IEC table to "last modified 17 September 2024," capturing the 17 September website update that added Denmark and Finland as new IEC destinations and adjusted the entries for Japan; and (ii) it replaces the prior long URL pointing to the table with a shorter, persistent address — www.bis.gov/IEC. The Director of the Federal Register approved the incorporation by reference.

Downstream implications

• Denmark- and Finland-resident purchasers of US-origin advanced

semiconductor, quantum, and additive-manufacturing items become eligible to receive those items under IEC rather than under specific BIS licence — reducing licence-processing friction for in-scope trade with two more EU member states.

• The simpler URL (www.bis.gov/IEC) is an operational improvement that

makes the legally-binding table easier to locate and cite, which matters because the table is the actual list of eligible items and destinations rather than the regulatory text itself.

• Adds a third European Economic Area data point (Denmark, Finland join

earlier IEC destinations) to the plurilateral perimeter that pairs with concurrent Japanese METI and Dutch ASML controls — consistent with the post-2024 US strategy of conditioning licence-exception benefits on partner-country regulatory parity.

Open questions

• Whether subsequent BIS rulemakings will use the simplified

www.bis.gov/IEC URL as the canonical citation form, and whether the table itself will be updated more frequently now that the website publication pathway is decoupled from the long-form Federal Register URL.

• How the modified Japan entries differ from the prior version — the

Federal Register notice does not summarise the substantive differences in detail; readers must consult the 17 September 2024 table directly.