Loading…
Loading…
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 Jan 16, 2025 interim final rule (FR Doc 2025-00711, 90 FR 5298) introduced new "Know-Your-Customer" / due-diligence procedures for advanced computing integrated circuits and made conforming amendments to ECCN 3A090. In the license-requirements table for 3A090, the published text read "RS applies to the entire entry, except 3A090.a" — the inverse of the policy intent. ECCN 3A090.a covers the highest-performance chips (TPP ≥ 4800 or specified performance density and TPP ≥ 1600), and the Regional Stability (RS) control regime is the primary lever BIS uses to perimeter exports of those chips to PRC and arms-embargoed destinations. The original wording would have removed the RS hook from .a — the actual target — and applied it to the lower-tier 3A090.b/c.
The Feb 14 correcting amendment swaps the cell to read "RS applies to 3A090.a", restoring intent. Because the Jan 16 IFR had only just gone into force, the operational impact of the typo on real shipments is believed to be near-zero — exporters reading the rule as a whole understood the policy. But the correcting amendment is necessary to make the regulatory text legally enforceable as intended.
This is a narrow technical correction (severity 2) — no new entities, no new product scope, no new license criteria. It is filed for completeness in the BIS Advanced Computing chip-rule lineage (Oct 2022 → Oct 2023 → Apr 2024 NAC split → Dec 2024 HBM/SME → Jan 2025 due-diligence IFR → Feb 2025 correction → May 2025 Huawei guidance), as the published version of any IFR in that chain governs how exporters file CCATS classifications and license applications.
3A090.a" — exporters of TPP ≥ 4800 chips to China continue to need a BIS license (no change to actual licensing posture).
designation; their existing RS controls (where applicable per other rows of the table) are unaffected by this correction.
the parent IFR's Know-Your-Customer / red-flag framework remains in force.
or the de minimis / FDPR scope established by the Dec 2 HBM/SME package.
in this register; once filed, this correction's responds_to should be updated to point at it.
May 13, 2025 AI chip guidance package — already filed) carry the corrected 3A090.a wording forward into the broader Advanced Computing rule set.