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Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
The rule operationalises the ICTS supply-chain authority created by Executive Order 13873 (May 2019) — the same legal scaffolding behind the earlier TikTok / WeChat / Kaspersky ICTS proceedings — and applies it for the first time to a hard-good sector.
Two technology layers are covered:
1. Vehicle Connectivity System (VCS). Defined as any hardware or software item installed in or on a completed connected vehicle that directly enables the function of transmission, receipt, conversion, or processing of radio-frequency communications at a frequency over 450 MHz. This sweeps in cellular modems, V2X modules, satellite-communications hardware, Wi-Fi/Bluetooth chips, and the firmware/software that runs them. 2. Automated Driving System (ADS). Covered software is any item "primarily designed for the operation of an ADS" — i.e., the perception, planning, and control stack of SAE Level 3+ vehicles. Hardware is not covered for ADS.
Two prohibition categories:
prohibited from importing or selling in the United States any completed connected vehicle that incorporates Covered Software (covered software dialed in for MY 2027+ vehicles).
from importing into the United States any Covered VCS Hardware (effective for MY 2030+ vehicles, or 1 January 2029 for hardware not associated with a specific model year).
A "covered" item is one designed, developed, manufactured, or supplied by a person owned by, controlled by, or subject to the jurisdiction or direction of China or Russia. This is a status-of-supplier test, not a country-of-origin test — a Covered Person can supply from a third country and still trigger the prohibition.
Compliance scaffolding:
importers attesting they are not engaging in prohibited transactions; required even for those not transacting with covered parties.
testing scenarios.
suppliers like Huawei (HiCar, ADS, MDC platform), DJI (Livox lidar), Horizon Robotics (Journey ADAS chips), Banma Network, ZeroTech, Quectel (cellular modules), and Cainiao-affiliated telematics vendors face structural prohibition by MY 2027/2030.
Stellantis, Honda, Toyota, Volkswagen, Hyundai-Kia, BMW, Mercedes, Volvo, Polestar) must trace every VCS/ADS sub-component to the ultimate developer/manufacturer — Tier-N visibility that the industry currently lacks. Transition cost is non-trivial.
Polestar (which produces the Polestar 2 and Polestar 4 in China) are the most exposed European-badge importers. Polestar 3 US-bound production was relocated to Volvo's South Carolina plant partly in anticipation of these rules.
effect for MY 2027 vehicles, which begin entering production in late summer/fall 2026. Compliance redesign cycles are 2-3 years, so OEMs were already in component-resourcing motion when the rule was published.
longer-cycle than software, so BIS gave a three-year additional runway. Practical effect: telematics modules and cellular modems continue to be sourced from Quectel/Fibocom/etc. through MY 2029, then must shift to non-Covered suppliers (Sierra Wireless, Telit Cinterion, U-blox, Murata, Qualcomm-direct).
the EO 13873 ICTS framework as a sectoral tool, not just a case-by-case (TikTok / Kaspersky) instrument. Drone and uncrewed aircraft systems are widely expected as the next sector.
of the Biden administration but uses an authority (EO 13873) originally signed by Trump in May 2019. The new administration has retained the rule and is widely expected to expand it.
jurisdictions (Iran, DPRK, Venezuela, Cuba) per the EO 13873 statutory list?
joint-ventures of US firms (e.g., Ford-Changan) producing software-defined vehicle stacks?
designed" threshold for ADS — will incidental ADS-adjacent components (sensor fusion middleware, V2X stacks) be pulled in?
signalled as the next ICTS sector after CVs?