BIS removes Cambodia from EAR Country Group D:5 (arms-embargo) in conforming change to State ITAR rule

Mechanism

The EAR's Country Group D:5 (Supplement No. 1 to Part 740) lists countries subject to a US arms embargo — a designation that triggers heightened license requirements across multiple ECCNs and disqualifies destinations from a wide range of license exceptions. Cambodia was added to D:5 in December 2021 by the first Biden BIS in parallel with State's ITAR §126.1 inclusion (citing PRC military-construction activity at Ream Naval Base and human-rights concerns). The 7 November 2025 State final rule ("International Traffic in Arms Regulations: Changes to Section 126.1") struck Cambodia from §126.1's arms-embargoed list; this 4 February 2026 BIS final rule is the matching EAR conforming change so that the EAR's D:5 list and ITAR's §126.1 list move in lockstep, "to avoid confusion on the part of exporters, reexporters, and transferors."

The change is narrow: only the D:5 "X" is deleted. Cambodia remains in Country Group D:1 (national-security concerns) and stays subject to the military end-use (§744.21) and military-intelligence end-use/end-user (§744.22) controls. The downstream implication is that the most restrictive arms-embargo licensing posture (which functioned as a near- prohibition on dual-use defense articles) is replaced by ordinary D:1 review, but commercial dual-use transactions to Cambodian defense or intelligence end-users remain license-required and policy-of-denial.

Downstream implications

• Marginal commercial impact — Cambodia is a small US export market and

D:5 designation primarily affected defense-articles and dual-use end-users, not the broader civilian economy. Severity 1 reflects the narrow downstream effect.

• Diplomatic signal is larger than the regulatory delta — the parallel

State ITAR change (Nov 2025) and this BIS conforming change together mark the end of the four-year US arms-embargo posture toward Phnom Penh that began in late 2021. Read in context with broader Trump- administration normalization of relations with Cambodia (post-July 2025 trade deal cycle).

• Dual-use exports to Cambodian military/intelligence end-users remain

controlled under §744.21/744.22 — exporters cannot infer general liberalization from this rule.

• No responds_to field populated: the precipitating action (State Dept

ITAR §126.1 amendment, 7 November 2025) is not yet filed in this register; should be queued separately by wake-discovery.

Open questions

• Does the parallel State ITAR rule (Nov 7, 2025) warrant its own action

filing? It is the substantive change; this BIS rule is purely conforming. If filed, this entry should be amended to add a responds_to: reference.

• Is a similar D:5 delisting under consideration for any other 2021-era

additions (e.g., Sudan, Russia/Belarus pathways)?