Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

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.

The US Bureau of Industry and Security amended the Export Administration Regulations to impose a new "Regional Stability – Pakistan" (RS-PAK) licence requirement on exports, reexports, and in-country transfers to Pakistan of items classified under six previously-uncontrolled-for-Pakistan ECCNs: 1B999, 2A992, 2B999 (excluding 2B999.h.2), 3A992, 3A999, and 6A996. The covered items — process-control equipment, high-pressure piping and valves, oscilloscopes, electronic test equipment, magnetometers, and related dual-use industrial gear — are associated with unsafeguarded nuclear and ballistic-missile end-uses. Licence applications are reviewed case-by-case to assess diversion risk to Pakistan's nuclear weapons or ballistic missile programmes, and to entities already on the Entity List or front companies acting on their behalf. Issued as a final rule under ECRA §1762(a) (no notice-and-comment); originally effective 25 November 2024 with the corresponding amendatory instructions, with the substantive licence requirement effective 26 December 2024 (post C1-2024-27648 correction published 29 November 2024).

The US Bureau of Industry and Security issued a final rule on 5 September 2024 (effective 6 September 2024, published in the Federal Register on the same day as 89 FR 73285) establishing multilateral export controls on four categories of emerging technologies: (1) quantum computing items including quantum computers, related cryogenic / control / measurement systems, and certain quantum software; (2) gate-all-around field-effect transistor (GAAFET) production technology — the next-node semiconductor architecture beyond FinFET; (3) advanced additive-manufacturing equipment for metals + alloys; (4) certain biotech-related items added in a parallel rule on 12 September 2024. The rule operates without country exceptions for some categories, with multilateral coordination via Wassenaar + Australia Group + Nuclear Suppliers Group frameworks.

BIS published a two-part final rule amending the Export Administration Regulations (EAR) for cameras, systems, and related components, effective March 8, 2024. Part one creates new ECCN 6A293 controlling ultra-high-speed cameras (minimum exposure time ≤1 microsecond AND throughput ≥13.43 Giga-pixels per second at 205,000 fps) for nuclear nonproliferation (NP) reasons with no License Exception STA eligibility, capturing instruments used in weapons-test diagnostics not previously covered by 6A003 or 6A203. Part two lifts military-end-user (MEU) restrictions on ECCNs 0A504, 6A002, 6A003, 6A993.a, and 8A002.d for Country Group A:1 destinations (32 closest US allies including EU member states, Canada, Japan, Australia, UK, and South Korea), aligning controls with commercial availability and established allied strategic relationships.

BIS added 28 entities to the EAR Entity List across seven countries, targeting four distinct threat clusters: a Russia GRU/UAV diversion network spanning China, Finland, Germany, and Russia; an Iran Shahed-series UAV procurement chain operating through Chinese front companies (designated under the Russia/Belarus Military End User FDP Rule); Pakistan-linked suppliers procuring for unsafeguarded nuclear activities; and two Oman-based entities supporting Yemen's Houthi forces. Russia's dominant titanium producer VSMPO-AVISMA was also added as a military end user. One Chinese entity (Zhejiang Perfect New Material) was simultaneously removed from the Military End User List.

Published August 29, 2023, this correction amends the Commerce Country Chart table (15 CFR Part 738, Supplement No. 1) to restore entries for the People's Republic of China and Macau under the Nuclear Nonproliferation (NP) column 2 that were erroneously omitted or mis-rendered in the August 21, 2023 correction notice (FR Doc 2023-18047). The correction is technically procedural but operationally significant: it formally establishes the NP2 "X" markings for China and Macau that trigger BIS licensing requirements for items in ECCNs 1A290, 1C298, 2A290, 2A291, 2D290, 2E001, 2E002, and 2E290. Prior to the underlying August 14, 2023 final rule, neither China nor Macau was subject to NP2 controls in the EAR.

Published August 21, 2023, BIS issued this correction to its August 14, 2023 final rule (FR Doc 2023-17243, 88 FR 55021) that expanded Nuclear Nonproliferation (NP2) licensing requirements for exports to the People's Republic of China and Macau. The correction addressed a typographical error in the Commerce Country Chart table (15 CFR Part 738, Supplement No. 1) as it appeared in the original Federal Register publication. The corrected tabular presentation introduced a secondary error that was subsequently fixed by a second correction notice (C1-2023-18047) published August 29, 2023; the substantive policy — NP2 licensing requirements for ECCNs 1A290, 1C298, 2A290, 2A291, 2D290, 2E001, 2E002, and 2E290 destined for China and Macau — was established by the original August 14 rule and remained unchanged throughout the erratum chain.

BIS published a final rule on August 18, 2023, amending the Export Administration Regulations (EAR) to implement decisions reached at the Nuclear Suppliers Group (NSG) plenary meetings in Nur-Sultan (June 2019) and Warsaw (June 2022). The rule revises five existing Export Control Classification Numbers (ECCNs) on the Commerce Control List (CCL) to align with multilateral commitments made by NSG participating governments. Changes include decontrolling water-hydrogen sulfide exchange tray columns from ECCN 1B22, clarifying isotope purification scope in ECCN 1B231, and updating mass-unit terminology in ECCN 3A233. The rule takes effect immediately upon publication.

Effective August 11, 2023, BIS amended 15 CFR Parts 738 and 742 to add the People's Republic of China and Macau to Nuclear Nonproliferation (NP2) licensing requirements under the Export Administration Regulations. The rule inserts NP2 "X" column markings for China and Macau in the Commerce Country Chart, subjecting exports of eight ECCN families (1A290, 1C298, 2A290, 2A291, 2D290, 2E001, 2E002, 2E290) to a BIS licence requirement. The measure was motivated by China's military modernisation, military-civil fusion strategy, and nuclear force expansion; prior to this rule, neither China nor Macau was subject to NP2 controls in the EAR.

The Bureau of Industry and Security added 24 entities across 26 entries to the Entity List, effective December 8, 2022, covering Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates. Three distinct enforcement clusters are addressed: Russian defense-electronics firms and their foreign affiliates supporting Russia's military-industrial base post-Ukraine invasion; Singapore-based front companies that supplied controlled items to PASNA, an Iran-based Specially Designated National; and Pakistani and Emirati entities engaged in unsafeguarded nuclear activities and ballistic-missile proliferation. One entity (Safe Technical Supply Co., LLC) was simultaneously removed from three entries covering Oman, Saudi Arabia, and the UAE.

The US Department of Commerce Bureau of Industry and Security (BIS) added 71 entities — 70 Russian and 1 Belarusian — to the Entity List, effective June 2, 2022, in direct response to Russia's further invasion of Ukraine on February 24, 2022. The entities were designated as military end users acquiring or attempting to acquire US-origin items in support of Russia's military, and are subject to a policy of denial for all items subject to the Export Administration Regulations (EAR). Sixty-six entities receive a "footnote 3" military end-user designation, while five face outright denial with no license exceptions available beyond humanitarian food and medicine.

At the Executive Branch's request, the US Nuclear Regulatory Commission issued an order suspending the general license authority in 10 CFR 110.21-110.24 for exports of source material, special nuclear material, byproduct material, and deuterium for nuclear end use to the Russian Federation, effective immediately on issuance (May 12, 2022) and published in the Federal Register on May 17, 2022. Exporters must now apply for a specific license under 10 CFR 110.31 for any such export to Russia, which the NRC evaluates case by case. The order followed the Executive Branch's determination that continued general-license exports to Russia were inimical to US common defense and security in the wake of the invasion of Ukraine.

The Department of Commerce Bureau of Industry and Security (BIS) added 91 entities (across 96 entries) to the Entity List under 15 CFR Part 744, in direct response to Russia's further invasion of Ukraine on 24 February 2022. The listed entities span ten destinations — Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and the United Kingdom — and include Russian military research institutes, shipbuilding facilities, aerospace and electronics manufacturers, and suspected front companies in third countries used to circumvent EAR controls. A license is required for all items subject to the EAR; the review policy is denial for 86 entities and case-by-case (for US Government-supported space programs) for five.

The U.S. Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding seven entities under seven entries to the Entity List, effective February 14, 2022, on nuclear nonproliferation and national security grounds. Five Pakistani engineering and chemical companies, one Chinese metal-powder manufacturer (Jiangsu Tianyuan Metal Powder Co. Ltd.), and one UAE-based trading company (Odyssey General Trading FZC) were determined to be acting contrary to US foreign policy or national security interests. All seven entries impose a license requirement covering all EAR-jurisdiction items, with no license exceptions available; the license review policy is presumption of denial for the Chinese entity and per 15 CFR § 744.2(d) for the Pakistani and UAE entities.

The US Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) effective November 26, 2021, by adding 28 entries to the Entity List across China (12), Japan (1), Pakistan (13 including 2 individuals), Singapore (1), and Taiwan (1). Designations span three distinct threat clusters: (1) eight Chinese entities supporting military applications of quantum computing, including QuantumCTek Co. and the Hefei National Laboratory for Physical Sciences at Microscale; (2) approximately twelve Pakistani procurement entities and three Chinese suppliers facilitating Pakistan's unsafeguarded nuclear activities and ballistic missile program; and (3) the Corad Technology network across China, Japan, Singapore, and Taiwan that sold Western technology to Iran's military/space programs and North Korean front companies. Additionally, the Moscow Institute of Physics and Technology was added to the Military End-User (MEU) List for producing military products. All Entity List entries carry presumption-of-denial licensing policy with no exceptions available.

The Bureau of Industry and Security (BIS) published a final rule, in conjunction with a companion NRC rulemaking, transferring export licensing authority for non-nuclear deuterium from the Nuclear Regulatory Commission to the Commerce Department under the Export Administration Regulations. Deuterium and deuterium compounds (including heavy water) with a deuterium-to-hydrogen atom ratio exceeding 1:5000 that are intended for non-nuclear end use are added to ECCN 1C298 and made subject to Nuclear Proliferation (NP) controls on the Commerce Country Chart. Exports to NP column 2–controlled destinations require a BIS licence; deuterium for actual nuclear-reactor end use remains under NRC jurisdiction.

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) added eight entities to the Entity List — six based in Pakistan and two in the UAE — on grounds that they were acting contrary to US national security or foreign policy interests through involvement in proliferation to unsafeguarded nuclear activities. All EAR items destined for these entities require a license with a presumption of denial; no license exceptions are available. Separately, one China-based entity (Molecular Devices Shanghai Corporation) was removed from the Military End-User (MEU) List, and a second China MEU entry was renamed (Hutchison Optel Telecom Technology → Chongqing Optel Telecom Technology Co., Ltd.).

BIS amended the Commerce Control List (CCL) under the Export Administration Regulations (EAR) to implement decisions agreed at the December 2019 Wassenaar Arrangement Plenary meeting, revising 22 ECCNs across nine CCL categories — including nuclear and conventional arms-related items, materials, manufacturing equipment, semiconductors, laser/sensor systems, and aerospace. The rule harmonises US controls with those of Wassenaar Participating States, maintaining competitive parity among allied exporters while preserving national-security licensing for non-partner destinations. Separately, the rule eliminated email notification and self-classification reporting obligations for most mass-market encryption products and publicly available encryption source code, reducing associated compliance submissions by an estimated 60–80%.

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.