Industrial Policy & Trade Monitor· 2665 actions· ✨ 90 recent

On 26 October 2025 in Kuala Lumpur, on the margins of the ASEAN Summit, President Donald J. Trump and Prime Minister Anwar Ibrahim signed two complementary instruments structuring the US-Malaysia economic relationship: (i) a non-binding Memorandum of Understanding Concerning Cooperation to Diversify Global Critical Minerals Supply Chains and Promote Investments, establishing quarterly working-level meetings on bilateral exploration, extraction, processing, refining, manufacturing, and recycling, plus shared commitments on streamlined permitting and protection from non-market policies; and (ii) a legally-binding Agreement on Reciprocal Trade (ART) covering goods (chemicals, machinery, electrical equipment, metals, vehicles, dairy, horticulture, poultry, pork, rice, fuel ethanol), digital trade, services, and investment. Under the ART, the United States maintains a 19% reciprocal tariff on Malaysian imports (with carve-outs for products receiving 0% under EO 14346) while Malaysia commits to refrain from banning or quota-restricting exports of critical minerals or rare earths to the US, ensure no restrictions on rare-earth magnet sales to US firms, and grant extended operating licenses to US partners. The ART enters into force 60 days after exchange of notifications of completed domestic procedures.

Regulation (EU) 2024/2847 of the European Parliament and of the Council on horizontal cybersecurity requirements for products with digital elements, signed 23 October 2024 and entering into force 10 December 2024. The CRA is the first EU statutory cybersecurity regime covering all hardware and software products with a direct or indirect data connection placed on the EU market, imposing essential cybersecurity requirements, conformity assessment with CE marking, mandatory vulnerability handling, and 24-hour early-warning notification of actively-exploited vulnerabilities to ENISA. Main manufacturer obligations apply from 11 December 2027; conformity-assessment-body notification provisions apply from 11 June 2026 and reporting obligations from 11 September 2026. Penalties reach EUR 15M or 2.5% of global annual turnover.

The U.S. Bureau of Industry and Security (BIS) published a final rule expanding the scope of the Iran Foreign Direct Product (FDP) rule in the Export Administration Regulations (EAR) to implement the "No Technology for Terror Act" (Public Law 118-50, Division N), signed by President Biden on April 24, 2024. The expanded rule extends EAR jurisdiction to additional foreign-produced items destined for Iran — including a broader set of items derived from U.S.-origin technology or software, or produced by plants/components that are themselves direct products of U.S.-origin technology — and requires a BIS license for their export, reexport, or in-country transfer to Iran. The rule also provides specified exclusions from the otherwise-applicable license requirements. The rule became effective on July 23, 2024 (publication July 26, 2024).

The Bureau of Industry and Security (BIS) issued a final rule (FR Doc 2024-08622; Docket 240417-0112; 89 FR 30119) amending the Export Administration Regulations (EAR) to expand the product scope of two Foreign Direct Product (FDP) rules — the Iran FDP rule and the Russia/Belarus/Temporarily occupied Crimea region of Ukraine FDP rule in 15 CFR 734.9(f) — to cover the entirety of the Common High Priority List (CHPL), an HTS-6 list developed jointly with the EU, Japan and the UK that identifies items used in Russian weapons production. The CHPL scope adds basic commercial-grade microelectronics (integrated circuits, RF transceiver modules), test/manufacturing equipment for electronic components, and CNC machine tools to the perimeter, requiring a BIS licence when these foreign-produced items are exported, reexported or transferred to Iran, Russia, Belarus or occupied Crimea. The rule was issued in response to Iran's 13 April 2024 attack on Israel and Iran's ongoing military support for the Russian war in Ukraine; it became effective 18 April 2024 (Federal Register publication 22 April 2024) with a transit grace period for in-flight shipments until 20 May 2024.

The Bureau of Industry and Security (BIS) established a new Iran Foreign Direct Product (FDP) rule and created Supplement No. 7 to Part 746 of the EAR, effective 24 February 2023, to address Iran's supply of UAVs to Russia for use against Ukraine. The rule adds twelve HTS-6 codes covering UAV-relevant components — aircraft engines, processors, capacitors, memories, and radio navigation equipment — many of which are EAR99 items outside existing ECCNs, requiring a new licence for exports and reexports to Iran. Simultaneously, the rule expands the existing Russia/Belarus FDP rule to cover these same items, closing a gap where foreign-produced items derived from US technology could transit to Russia via Iran without triggering EAR licence requirements.