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

Turkish President Erdoğan signed Presidential Decision No. 11068 on 16 March 2026, published in the Resmî Gazete on 17 March 2026, establishing a mandatory pre-clearance regime for the transit passage and re-export of controlled military items through Türkiye's customs territory. Covered items include military vehicles and defence equipment, weapons and ammunition and their spare parts, military explosives, and dual-use technologies associated with these categories, as defined under Law No. 5201. Any entity seeking to move such goods through Türkiye must obtain a "uygunluk yazısı" (compliance letter) from the Ministry of Trade, which reviews applications in consultation with relevant public institutions. The measure directly operationalises Türkiye's response to sustained US pressure over Iran-related sanctions evasion via Turkish transit corridors and entity-list additions naming Türkiye-based diversion networks.

The National Defense Authorization Act for Fiscal Year 2026 (P.L. 119-60), signed into law on 18 December 2025, expands the Department of Defense's existing "covered materials" domestic- sourcing restriction (which already barred DoD contracting for SmCo/NdFeB magnets, tantalum and tungsten sourced from China, Russia, Iran or North Korea) to add gallium, germanium and molybdenum under Section 844. Restrictions on materials "melted or produced" in a covered nation take effect 31 December 2026, widening on 1 January 2027 to also cover materials "mined, refined, or separated" in a covered nation; the gallium/germanium additions specifically phase in on 18 December 2027. The same NDAA bundles two related supply-chain provisions: Section 867 gives DoD broader authority (contracts, grants, other-transaction agreements, equity-style investments, and anti-market-manipulation subsidies) to invest in the domestic industrial base for critical minerals, microelectronics, machine tools and other defense-relevant capacity, and Section 842 bars DoD from procuring advanced batteries whose cells or key components are owned, sourced, refined or produced by a foreign entity of concern, phased in 2028-2031.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 29 entries — 26 entities and 3 addresses — to the Entity List under the destinations of China (19), Turkey (9), and the United Arab Emirates (1). BIS determined these parties were diverting US-origin items to Iran, including to parties already on the BIS Entity List and on OFAC's Specially Designated Nationals (SDN) List, in support of Iranian drone-parts and electronics-procurement networks. The rule is a final rule effective October 8, 2025; new license requirements apply to all items subject to the EAR for these listed parties under a presumption-of-denial review policy.

Japan's Ministry of Economy, Trade and Industry (METI) revised its Foreign End-User List (外国ユーザーリスト) — the reference list of foreign organisations for which WMD/missile or, for the first time, conventional-weapons development concerns cannot be excluded, used to trigger catch-all export-licence requirements. The revision adds 92 entities (from China, Hong Kong, North Korea, Russia, Pakistan, Iran and the UAE) and removes 5 entities (from China, Iran and India), taking the list to 835 entities across 15 countries and regions — a net increase of 87. The revised list applies from 9 October 2025, the same date Japan's broader catch-all conventional-weapons supplementary export-control review took effect.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 32 entities to the Entity List, with the largest bloc — 23 entries — under the destination of China, plus India (1), Iran (1), Singapore (1), Taiwan (1), Turkey (3), and the United Arab Emirates (2). The rule also removed two addresses from one Russian entry (Intertech Rus LLC) and made 27 typographical corrections to existing entries. Several Chinese additions — including Shanghai Fudan Microelectronics, Sino IC Technology, GMC Semiconductor (Wuxi), and Chinese Academy of Sciences units (National Time Service Center; Aerospace Information Research Institute) — were given footnote 4 designations, extending the EAR's foreign-direct-product (FDP) reach to non-US-origin items destined for Russian military end use. Three Turkish entries (Atempo, EB Teknoloji, Dentun Elektronik) and one Indian entry (AR Sales Pvt Ltd) were footnote-3 Russian Procurement Entity designations. The rule is a final rule effective September 12, 2025; all listed parties are subject to a license requirement for all items subject to the EAR with a presumption-of-denial review policy.

Taiwan's Ministry of Economic Affairs International Trade Administration (MOEA-ITA) amended the Strategic High-Tech Commodities (SHTC) export-control Entity List on 10 June 2025 (announced 15 June 2025) under Article 13 of the Trade Act, adding 601 new entities — including Huawei Technologies Co. Ltd. and Semiconductor Manufacturing International Corp. (SMIC) plus 599 additional entities domiciled in China, Russia, Iran, Pakistan and Myanmar. Taiwanese exporters (TSMC, UMC, ASE, KYEC and downstream suppliers) must obtain pre-export government licences for direct or third-party shipments of any SHTC-listed item to the listed entities; the action expands Taiwan's total entity-list population to ~10,844 entities. Two follow-on amendments tightened the regime further: a +279-entity expansion on 18 September 2025 and an 18-item commodity-list expansion on 18 November 2025 covering advanced 3D printers, semiconductor manufacturing equipment, electron microscopes and quantum-computing hardware.

In its first major export-regulatory action of the second Trump administration, BIS amended the EAR to add 70 entities to the Entity List under the destinations of China (42), Iran (2), Pakistan (19), South Africa (3), and the United Arab Emirates (4), and modified four existing entries (France, Iran, Senegal, UK). New listings carry a license requirement for all items subject to the EAR with a presumption-of-denial review policy and no license exceptions available. Stated objectives include restricting China's acquisition of high-performance computing and quantum technologies for military use, impeding hypersonic-weapons development, disrupting Iran's UAV and defense procurement, and impairing Pakistan's unsafeguarded nuclear and ballistic-missile programs. The rule also targets the Test Flying Academy of South Africa for using U.S.-origin items to train Chinese military pilots.

On 16 January 2025 the US Bureau of Industry and Security published an interim final rule (90 FR 4598; FR Doc 2025-00723) creating new ECCN 3A069 for high-parameter flow cytometers and liquid chromatography mass spectrometers specially designed for top-down proteomics, plus new ECCN 3E069 for related development and production technology. Items previously controlled under the catch-all ECCN 3A999 are migrated into the dedicated 3A069 classification, which carries National Security (NS), Regional Stability (RS), and Anti-Terrorism (AT) controls. Licensing policy is presumption of denial for destinations in Country Group D:1 and D:5, Macau, and Country Group E (i.e. China, Russia, Iran, North Korea, Cuba, Syria, Venezuela). The rule also adds new EEI/AES filing requirements (§ 758.1(b)(11)) for all 3A069 exports to Country Group D destinations. Public comments were accepted until 17 March 2025.

On 23 December 2024 the US Bureau of Industry and Security published a final rule (89 FR 104408; FR Doc 2024-30425; RIN 0694-AJ83) amending the Export Administration Regulations to implement decisions adopted at the Australia Group's 2023 and 2024 plenary meetings. The rule adds new ECCN 2B352.k controlling instruments for the automated chemical synthesis of peptides that are partly or entirely automated and capable of generating peptides at a system-synthesis scale of 1 mmol or greater, finalising the April 2023 BIS proposed rule. It also adds dipropylamine to ECCN 1C350.d.11, neosaxitoxin to ECCN 1C351.d.12, revises the 1C351.d.3 entry from "botulinum toxins" to "botulinum neurotoxins" to capture all serotypes, adds a "minimum detection limit" definition for toxic-gas monitors in 2B351.a, and explicitly captures single-use centrifugal separators in 2B352.c. License requirements (CB, AT, CW where applicable) apply for export to non-Australia-Group destinations; the rule is effective on publication.

Council Regulation (EU) 2024/2897 of 18 November 2024 amends Regulation (EU) 2023/1529 (restrictive measures over Iran's military support to Russia's war against Ukraine and to armed groups in the Middle East and Red Sea region). It replaces Annex II with an expanded list of goods and technology whose sale, supply or export to Iran is prohibited where they could enable UAV or missile production, across ten technology categories, and adds Article 2a, a prohibition on transactions with the ports listed in Annex IV (Amirabad and Anzali). It entered into force on publication in the Official Journal.

The US Bureau of Industry and Security (BIS) final rule (89 FR 68544; FR Doc 2024-19130) added 123 entities under 131 entries to the Entity List with destinations Russia (63), China (42), Iran (11), Turkey (8), and one each in Canada, Cyprus, Kazakhstan, Kyrgyzstan, Crimea Region of Ukraine, Ukraine, and the United Arab Emirates. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish and other third-country firms (e.g., MAK Logistics, Megatek Ltd., Wellgo International, AllChips Limited, Chipgoo Electronics) named for supplying U.S.-origin electronics and dual-use items to Russian industry and military, plus designation of large numbers of Russian military manufacturers (e.g., JSC 75 Arsenal, FSE Aleksinsky Chemical Plant) as military end users. License requirement is "all items subject to the EAR" with policy/presumption of denial; case-by-case for EAR99 food and medicine to certain Russian military end users. Effective on publication 2024-08-27.

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 US Bureau of Industry and Security (BIS) final rule (89 FR 25503; FR Doc 2024-07760) added 11 entries to the Entity List under China (6), Russia (3), and the United Arab Emirates (2), effective 2024-04-11. The primary rationale for the Russia and UAE tranches — and at least one China entity (Shenzhen Jiasibo Technology) — is procurement of US-controlled dual-use aerospace and UAV components for Iran's Shahed- series UAV programme via the Iran Aircraft Manufacturing Industrial Company (HESA); those drones have been used against oil tankers in the Middle East and deployed by Russia in Ukraine. The remaining five China entities were designated for acquiring US-origin items to support China's military modernisation. The rule also adds one alias to the existing entry for Shanghai Biren Intelligent Technology Co., Ltd. This action was the first Entity List final rule published after BIS implemented the 50 Percent Rule for controlling foreign subsidiaries of listed entities.

BIS final rule (FR Doc 2024-01408, 89 FR 4804, effective 23 January 2024) strengthens the EAR sanctions architecture against Russia and Belarus by adding 94 HTS-6 entries to the Russian and Belarusian Industry Sector Sanctions (§746.5/§746.8) — covering hand tools, parachutes, aircraft training simulators, and airplane/helicopter components — and expands the de minimis threshold for foreign-made goods incorporating US-origin 600-series and 9×515 items destined for Russia or Belarus. A parallel provision targets Iran's supply of unmanned aerial vehicles (UAVs) to Russia by adding HTS code 852910 (antennas and antenna reflectors) to the §746.7 Iran export-control list. The rule also refines Crimea licensing to permit exports supporting Ukrainian Armed Forces deployments in occupied territories.

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.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding seven Iranian entities to the Entity List effective 31 January 2023, for contributing to Russia's military and defense industrial base through the production and transfer of Iranian unmanned aerial vehicles (UAVs) used by Russia in Ukraine. The entities — including Shahed Aviation Industries, Qods Aviation Industry, and arms of the Islamic Revolutionary Guard Corps — are subject to a license requirement with a presumption of denial for all EAR-jurisdiction items. The rule applies the Russia/Belarus Military End User Foreign Direct Product (FDP) rule to all seven entities, extending its reach to foreign-produced items destined for or routed through these Iranian UAV producers.

BIS finalized changes to the Export Administration Regulations (EAR) governing controls on cybersecurity items — primarily intrusion software, command-and-control platforms, and surveillance tools capable of disrupting or monitoring information systems without authorization. The final rule, effective May 26 2022, revises License Exception ACE (Authorized Cybersecurity Exports) originally established by an October 2021 interim rule and narrows end-user carve-outs for government end users in Country Group D:5 and A:6 destinations. Exports of affected ECCNs (4A005, 4D001, 4D004, 4E001, 5A001.j, 5B001, 5D001, 5E001) to Country Groups E:1 and E:2 remain prohibited; D:1 through D:5 government-end-user transactions require a license.

BIS published an interim final rule on October 21, 2021 establishing new Export Control Classification Numbers (ECCNs 4A005, 4D004, 4E001.c, and 5A001.j) for intrusion software systems, command-and-control platforms, and IP network surveillance tools, implementing the Wassenaar Arrangement 2017 cybersecurity decisions into the Export Administration Regulations (EAR). The rule simultaneously created License Exception ACE (Authorized Cybersecurity Exports), codified at § 740.22, to authorize exports to most destinations while imposing licence requirements — or outright prohibitions — for sales to Country Groups E:1/E:2 governments and certain D-group government end-users. Carve-outs for vulnerability disclosure and cyber-incident-response activities were included to protect legitimate security research. The effective date was subsequently delayed from January 19, 2022 to March 7, 2022 by a separate interim rule (FR 2022-00448), and the rule was finalized with revisions on May 26, 2022 (FR 2022-11282).

The Bureau of Industry and Security amended the Export Administration Regulations by adding 34 entities under 43 entries to the Entity List, effective July 12, 2021. The largest cluster — 14 Chinese entities — comprises suppliers of surveillance infrastructure enabling the Chinese government's human-rights abuses in Xinjiang, including video analytics firms, network equipment makers, and geolocation platforms deployed in the Uyghur Region. Six Russian individuals and entities were added for participation in military procurement networks acquiring US-origin electronics and components in violation of the EAR. Additional listings cover Iran sanctions evaders (Canada, Lebanon), a UAE-based nuclear-proliferation facilitator, and one entity elevated from the Unverified List to the Entity List under China. All items subject to the EAR require a BIS licence to export, re-export, or transfer in-country to the listed parties, with a presumption-of-denial review policy.

The Bureau of Industry and Security (BIS) issued an interim final rule on January 15, 2021 substantially expanding the Export Administration Regulations (EAR) Part 744 end-use and end-user control framework to cover military-intelligence entities in China, Cuba, Iran, North Korea, Russia, Syria, and Venezuela. The rule created a new license requirement for exports of ANY EAR-subject item to named military-intelligence end-users — including EAR99-classified items — and separately imposed restrictions on U.S. persons worldwide providing "support" to military-intelligence end-uses or end-users without a BIS licence. It also broadened chemical and biological weapons controls from "will directly assist" to "will support," expanding the reach of §744.4 and §744.3 on WMD-delivery systems. A technical correction published March 17, 2021 (FR Doc 2021-05623) fixed a drafting error in Instruction 9 that would have inadvertently deleted §744.3(a)(3)(i)-(ii), the rocket systems and UAV provisions.

The US Bureau of Industry and Security (BIS) added 47 entities across 51 entries to the EAR Entity List effective 22 September 2020, covering entities in China, Hong Kong, Iran, Pakistan, Canada, Malaysia, Oman, Thailand, Turkey, the UAE, and the UK. All 47 entities were determined to be acting contrary to US national security or foreign policy interests. For 39 of the 47 entities BIS imposed a license requirement for all EAR-subject items with a presumption-of-denial review policy; the remaining eight face case-by-case review. The round targeted Iranian dual-use procurement networks, Chinese military-affiliated research institutes, and Pakistan-linked proliferators, reinforcing the layered export-control perimeter across multiple adversary programs simultaneously.