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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.
This is a routine ERC housekeeping rule under 15 CFR Part 744. By unanimous vote (the threshold required for any removal or modification under §744.16), the End-User Review Committee removed the entry for Arrow China Electronics Trading Co., Ltd. and trimmed six aliases off the Arrow Electronics (Hong Kong) Co., Ltd. entry. The Hong Kong parent remains on the Entity List; the six removed aliases will no longer be treated as named end-users for Entity List license requirements.
The ERC cited:
relationships of the aliases (i.e., that some of the alias names did not correspond to operationally distinct parties owned/controlled by the listed entity); and
undertaken by the affected parties.
In isolation this is a narrow, technical de-escalation:
altering the overall Entity List perimeter or any of the structural US-China export-control rulesets (chip-equipment, advanced computing, HBM, AI-diffusion).
listed, so the broader posture toward Arrow's HK operations is unchanged.
parties demonstrate genuine compliance reform → ERC unanimously votes to remove or modify. It is not a policy shift, but a procedural outcome.
It is filed here primarily as a structured data point in the Entity List churn series — the 2025-26 register tracks both additions (escalation) and removals (de-escalation) so that downstream consumers can compute net listing pressure on China by quarter.
electronics-distribution footprint: one PRC subsidiary no longer requires Entity List license review for EAR-controlled re-exports routed through it; six alias names previously triggering the HK parent's restrictions no longer do.
contemporaneous additions (e.g., FR Doc. 2025-19508, additions of 19 China entries on 2025-10-09) — but only at the margin (1 entity + 6 aliases vs. 19 new China entries).
suspension window (2025-11-10 – 2026-11-09): structural perimeter paused, but case-by-case ERC adjudication continues.
or operational entities that have since been wound up. The rule does not enumerate the alias names in the public summary.
rationale is documented anywhere outside the FR notice (e.g., a consent-style undertaking) — typically these are not published.