Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

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.