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

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) issued a final rule suspending, for one year, the interim final rule "Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities" (90 FR 47201, Sept. 30, 2025). Effective November 10, 2025 and ending November 9, 2026, the amendments to 15 CFR parts 732, 734, 736, 744, and 748 made by the Affiliates Rule are stayed; the original Entity List restrictions on named parties remain in force, but the automatic 50%-ownership-based extension to unlisted affiliates is paused. Phase two — re-instating the Affiliates Rule changes — is scheduled for November 10, 2026 absent a future extension.

The Bureau of Industry and Security (BIS) issued a final rule (FR Doc. 2025-19858; 90 FR 50858) removing Arrow China Electronics Trading Co., Ltd. from the Entity List under the destination of China and removing six aliases associated with Arrow Electronics (Hong Kong) Co., Ltd. (which itself remains listed but with a narrower alias footprint). The End-User Review Committee (ERC) made the decision by unanimous vote on the basis of information received pursuant to 15 CFR §744.16 regarding the relationships of the aliases and the parties' commitments to enhance export-compliance measures. Effective November 10, 2025.

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.

The Bureau of Industry and Security (BIS) issued an Interim Final Rule amending the Export Administration Regulations (EAR) to automatically extend Entity List, Military End-User List, and certain other restricted- party controls to any unlisted entity that is at least 50% owned — individually or in the aggregate — by one or more listed parties. The threshold is set to mirror the long-standing OFAC 50% rule. Published 90 FR 47201 (Sept. 30, 2025); effective Sept. 29, 2025. A Temporary General License covering pre-existing transactions with 50%-owned affiliates expired on Nov. 28, 2025. The rule was subsequently suspended for one year by BIS on Nov. 10, 2025 (FR Doc. 2025-19846) as part of the post-Busan US-China understanding.

The Bureau of Industry and Security (BIS), within the U.S. Department of Commerce, published a final rule in the Federal Register on September 30, 2025 (FR Doc 2025-18992) rescinding the April 30, 2024 Firearms Export License Requirements interim final rule in its entirety, with the sole exception of preserving the new Export Control Classification Numbers (ECCNs) it had introduced for firearms and ammunition. The rule also amends the EAR to remove the Congressional notification requirement for certain semi-automatic firearms license applications. It is effective on publication.

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.

On 2 September 2025 the Bureau of Industry and Security (BIS) published a final rule (90 FR 42315; FR Doc 2025-16724) revising the Export Administration Regulations (EAR) to substantially relax export and reexport controls on Syria, consistent with Executive Order 14312 ("Providing for the Revocation of Syria Sanctions", 30 June 2025) and the parallel post-Assad sanctions architecture (PAARSS, OFAC, 25 Sep 2025). The rule (i) revises previously restrictive licence-application review policies for items subject to the EAR to be more favourable, (ii) extends the geographic eligibility of existing license exceptions to Syria, and (iii) adds new license exceptions for Syria including for EAR99 items. The rule is effective on publication; section 6 of EO 14312 had already waived application of section 5(a)(1) of the Syria Accountability Act with respect to items on the Commerce Control List, and section 7 waived CBW Act sections 307(a)(5) and 307(b)(2)(C) restrictions on EAR-subject exports to Syria.

The US Bureau of Industry and Security (BIS) amended the Export Administration Regulations to remove three foreign-owned semiconductor fabs operating in China — Intel Semiconductor (Dalian) Ltd, Samsung China Semiconductor Co. Ltd, and SK hynix Semiconductor (China) Ltd — from the Validated End-User (VEU) Authorizations list (15 CFR Part 748). BIS framed the VEU program as a "loophole" that previously allowed these fabs to receive most US-origin chipmaking equipment, software and technology license-free, a privilege no US-owned fab in China ever had. After the effective date, every restricted shipment to these fabs will require an individual export license, reviewed case-by-case under the existing 2022/2023 advanced- computing controls. The rule is published as Federal Register document 2025-16735 (90 FR 42321), Docket BIS-2025-0555, RIN 0694-AK32.

On 23 May 2025 the Bureau of Industry and Security notified major electronic design automation (EDA) suppliers — Cadence Design Systems, Synopsys, and Siemens EDA — by letter that a license is now required for any export, re-export, or in-country transfer of EDA software and technology classified under ECCNs 3D991 and 3E991 where a party to the transaction is located in China or is a Chinese "military end user" wherever located. BIS determined the shipments posed an unacceptable risk of diversion to Chinese military end use. The action was not published as a Federal Register rule; it surfaced publicly only through the affected companies' SEC 8-K disclosures. Synopsys suspended its FY2025 financial guidance in response. BIS rescinded the requirement effective 2 July 2025 (see amendments) amid the broader US-China trade truce, and the three vendors restored access for affected customers.

On 13 May 2025, two days before the AI Diffusion Rule's primary 15 May 2025 compliance date, the Trump administration's BIS announced it would rescind the Biden-era Framework for AI Diffusion (90 FR 4544) and simultaneously issued three guidance documents that re-routed US AI export policy through existing EAR authorities. The package comprises (1) GP10 guidance asserting that all ECCN 3A090 ICs designed by PRC-headquartered firms are presumptively EAR-violative, with Huawei Ascend 910B/910C/910D processors named explicitly — making US- and non-US-person use, transfer, financing, or servicing of those chips anywhere in the world a presumptive General Prohibition 10 violation; (2) a policy statement warning industry that supplying US advanced computing ICs for training or inference of Chinese AI models risks EAR enforcement; and (3) industry guidance on diversion-prevention diligence. BIS stated a formal Federal Register rescission and replacement rule would follow.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 18 persons to the Unverified List (UVL) and removing 5. Of the 18 additions, 5 are under China, 6 under Finland, 3 under Türkiye, 2 under Kazakhstan, 1 under Italy, and 1 under the United Kingdom — a geographic distribution dominated by Russia-adjacent diversion corridors. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends use of EAR license exceptions for shipments to listed parties and requires US exporters to obtain a UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 25 April 2025 (90 FR 17339).

The US Bureau of Industry and Security amended the Export Administration Regulations to add 12 entities to the Entity List under the destinations of China (11) and Taiwan (1) via Final Rule 2025-05427 (90 FR 14046), companion to the larger 70-entity rule (2025-05426) published the same day. Targets fall in three clusters: (i) Beijing Academy of Artificial Intelligence and Beijing Innovation Wisdom Technology — added for acquiring US-origin items in support of China's military modernization, specifically developing large AI models and advanced computing chips for defense; (ii) the Inspur group — Inspur (Beijing) Electronic Information Industry, Inspur Electronic Information Industry, Inspur Electronic Information (Hong Kong), Inspur (HK) Electronics, Inspur Software, and Inspur Taiwan — added as subsidiaries contributing to supercomputers for military end use; and (iii) Henan Dingxin, Nettrix Information Industry, Suma Technology, and Suma-USI Electronics — added for involvement in the development of Chinese exascale supercomputers. License requirements are for all items subject to the EAR; review policy is presumption of denial for the AI cluster and policy of denial for the supercomputer clusters.

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.

BIS published a correcting amendment to its January 16, 2025 interim final rule "Implementation of Additional Due Diligence Measures for Advanced Computing Integrated Circuits" (FR Doc 2025-00711). The correction revises the license-requirement table for ECCN 3A090 by changing the first row, first column from "RS applies to the entire entry, except 3A090.a" to "RS applies to 3A090.a", aligning the Regional Stability control scope with BIS's intended policy in the Advanced Computing Chip rules. Effective February 11, 2025; comments due March 14, 2025. Docket BIS-2024-0055; RIN 0694-AJ98.

BIS published an interim final rule (FR Doc 2025-00711, 90 FR 4544-publication slot; companion to the AI Diffusion Framework signed three days earlier) revising the EAR to add explicit due-diligence procedures for advanced computing integrated circuits captured by ECCN 3A090. The rule (i) creates an Authorized IC Designer / Approved IC Packager regime so that foundries and OSATs can identify trustworthy customers via lists maintained by BIS, (ii) imposes new front-end-fabricator reporting requirements for any 3A090.a IC produced for an authorized IC designer to give the US government supply-chain visibility, and (iii) adjusts the scope of covered advanced-computing items. Effective 16 January 2025; compliance required from 31 January 2025; comment period extended to 14 March 2025. The rule was immediately followed by the 16 January Entity List additions (Sophgo et al.) targeting circumvention paths and was technically amended on 14 February 2025 to narrow the RS license requirement to ECCN 3A090.a only.

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.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 11 entities under 11 entries to the Entity List, all listed under the destination of China, People's Republic of (China). The rule also revises one existing entry on the Entity List under the destination of India. BIS determined the added entities have been involved in, are involved in, or pose a significant risk of becoming involved in activities contrary to the national security or foreign policy interests of the United States. License requirements apply to all items subject to the EAR with a presumption-of-denial review policy. The rule was effective on publication, January 16, 2025. This action is the companion piece to the same-day 16-entity Sophgo-cluster addition (FR 2025-00480) — together totalling the "27 Chinese companies" referenced in trade-press coverage.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 16 entities to the Entity List under the destinations of China (14) and Singapore (2). The additions concentrate on the Sophgo Technologies cluster and a set of affiliated PRC fabless / system houses (Suanze, Suanxin, Suanhu, Suanli, Suanneng, Sophon, Quliang, Shunhua) plus two Singapore entities (Sophgo Technologies Pte. Ltd., PowerAir Pte. Ltd.) acting as offshore extensions of the same group. BIS cites involvement in "supporting or directly contributing to the development of advanced computing integrated circuits" that further PRC advanced-weapons, WMD, and high-tech surveillance programs. License requirement covers all items subject to the EAR with a presumption-of-denial review policy. The rule was effective on publication, January 16, 2025.

The Bureau of Industry and Security signed an Interim Final Rule on 13 January 2025 (90 FR 4544, published 15 January 2025) introducing the first horizontal export-control regime for advanced AI compute and closed-weight model weights. It revised ECCN 3A090 advanced-IC thresholds, created a new ECCN 4E091 covering closed-weight model weights trained on more than 10^26 operations, and bucketed every destination worldwide into a three-tier country group: Tier 1 (~18 close allies, license-free flows), Tier 2 (the rest of the world, per-country compute caps with National VEU and Universal VEU pathways), Tier 3 (US arms-embargoed destinations including China and Russia under comprehensive denial). It added license exceptions AIA, ACM, and LPP and set staggered compliance dates of 15 May 2025 (general) and 15 January 2026 (data-center / model-weight provisions). The Trump administration's BIS rescinded the rule on 13 May 2025 — two days before the primary compliance date — but it was on the books for four months and shaped allied compliance build-out and the architecture of subsequent US AI export controls.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 entities under 13 entries to the Entity List, listed under the destinations of Burma (1), China (11), and Pakistan (1). The PRC additions concentrate on the optics/photonics, RF/microwave, and military-civil-fusion research-institute layer of China's military-modernization stack — including CAS Changchun Institute of Optics, Fine Mechanics and Physics (CIOMP), Shanghai Institute of Optics and Fine Mechanics (SIOM), Peng Cheng Laboratory, Ji Hua Laboratory, and the Yaguang/Chengdu RML defense-electronics cluster — with explicit references to support for hypersonic-weapons development. The Burma entity is Telecom International Myanmar (Mytel), added for providing surveillance services and financial support to the post-coup military regime; the Pakistan entity (Emerging Future Solutions Pvt Ltd) was added for contributions to Pakistan's ballistic-missile programme. All 13 entries carry a license requirement for all items subject to the EAR with a presumption-of-denial review policy and no license exceptions. The rule was effective on publication, January 6, 2025, with a savings clause through February 5, 2025 for goods already en route.