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

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.

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.

South Korea's Ministry of Trade, Industry and Energy issued the 36th amendment to the Public Notice on Export and Import of Strategic Items (전략물자수출입고시) as MOTIE Notice No. 2025-20, with promulgation on 24 February 2025 and effect from 28 February 2025. The amendment adds 21 advanced-technology items and technologies — including quantum computers, AI-class semiconductors, 3D-printing equipment, isotopes for quantum computing, ultra-low-temperature measurement equipment, and high-temperature coatings — to the Strategic Items List, implementing recent updates from the Wassenaar Arrangement, Nuclear Suppliers Group, Missile Technology Control Regime, and Australia Group multilateral export-control regimes. The same amendment introduces a humanitarian-medical-device carve-out for exports of diagnostic X-ray and radiographic imaging equipment to Russia, simplifies end-user verification (intermediaries deemed final end-user where verification is "extremely difficult"), extends the post-transaction reporting period from 7 days to 3 months, creates a self-disclosure system for non-compliance, and allows one-time extensions of individual export licences beyond original validity.

Japan's Ministry of Economy, Trade and Industry (METI) revised its Foreign End-User List, the reference list of foreign organisations for which concern cannot be eliminated regarding involvement in the development of weapons of mass destruction and missiles, used to support catch-all export-licence requirements. The revision added 42 entities, taking the list to 748 entities from 15 countries and regions, and applies from 5 February 2025.

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.

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).

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.

On 31 October 2024, South Korea's Ministry of Foreign Affairs announced strengthened export controls in response to North Korea's long-range ballistic missile launch earlier that day. The measure designates 15 "North Korea-customized" watch-list items across the solid-fuel missile production chain — including ammonium perchlorate, sodium chloride, liquid thiokol, carbon fiber, glass fiber fabric, thermal batteries and inertial-guidance components — that North Korea finds difficult to produce domestically. It operates under Korea's existing Special Notice on Trade for Fulfilling International Peace and Security Obligations, building on the June 2016 Nuclear and Missile Surveillance Items framework and Korea's NSG/MTCR commitments.

Bureau of Industry and Security final rule (89 FR 84460, Doc 2024-24562) adding 26 entities to the Entity List across four destinations: six in China (aviation simulation for PLA modernisation; procurement for Iran WMD/UAV programs; evasive conduct), one in Egypt and three in the UAE (acquiring US civil aircraft parts for Russian buyers post-Ukraine invasion), and sixteen in Pakistan (nine front companies of Advanced Engineering Research Organization for Pakistan's cruise-missile and strategic-UAV programs, plus seven contributing to Pakistan's ballistic- missile program). The rule also removes two existing entries. All additions are licensed under a presumption-of-denial policy for all EAR-subject items.

Premier Li Qiang signed State Council Decree No. 792 on 19 October 2024 promulgating the Regulations of the People's Republic of China on Export Controls for Dual-Use Items, with effect from 1 December 2024. The regulation, organised in six chapters and 50 articles, consolidates the previously fragmented nuclear / biological / chemical / missile dual-use control regimes into a single State Council framework operationalising the 2020 Export Control Law. It introduces a control-list / temporary-control / watchlist architecture, a statutory end-user / end-use commitment regime, transit / transhipment / re-export controls, extraterritorial reach over PRC items downstream, and explicit linkage to the Anti-Foreign Sanctions Law. On 15 November 2024 MOFCOM, MIIT, GAC and SCA jointly issued Announcement No. 51 of 2024 publishing the consolidated Dual-Use Items Export Control List with a unified five-character ECCN-style coding system, also effective 1 December 2024.

The Defence and Strategic Goods List (DSGL) 2024 was registered on the Federal Register of Legislation on 16 August 2024 under the Customs Act 1901 and Defence Trade Controls Act 2012, repealing and replacing the DSGL 2021. It comprises the Munitions List (Part 1) and the Dual-Use List (Part 2, nine technology categories including nuclear materials, chemicals, electronics, sensors and marine and aerospace equipment) that Australia controls for export, brokering and intangible transfer. The 2024 instrument periodically realigns the list with changes agreed in the multilateral non-proliferation and export-control regimes Australia belongs to (Wassenaar Arrangement, Missile Technology Control Regime, Nuclear Suppliers Group, Australia Group); most changes are clarifications to existing controls, with a smaller number of items entering or leaving control or having their approval requirements adjusted.

The US Bureau of Industry and Security (BIS) issued an interim final rule (IFR) amending the Export Administration Regulations (EAR) to remove list-based license requirements — including National Security Column 1 (NS1), Regional Stability Column 1 (RS1) and Missile Technology Column 1 (MT1) reasons-for-control — for exports, reexports and in-country transfers to or within Australia and the United Kingdom. The IFR also expands the availability of license exceptions and reduces the scope of end-use and end-user-based license requirements for the two AUKUS partners, while leaving firearms-related items (Crime Control / CC) and a narrow set of other ECCNs untouched. The rule is the EAR-side companion to a parallel DDTC proposed rule creating an ITAR §126.7 exemption for defense articles and services traded among authorised AU/UK/US users, and is the foundational regulatory implementation of the AUKUS Pillar 2 advanced-capability cooperation track.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to implement changes to the Missile Technology Control Regime (MTCR) Annex agreed at Technical Experts Meetings in 2018, 2019, and 2021, revising six ECCNs (1C111, 2A101, 2B119, 6A107, 9A101, and 9E515). The rule simultaneously expands license exception eligibility for MT-controlled items — adding one new authorization and broadening four existing exceptions — for exports to allies and partners not in Country Groups D:4 or D:5. BIS estimates the changes will reduce MT-related license applications by approximately 400 per year, easing compliance burden on defence and aerospace exporters dealing with allied governments.

BIS issued a correcting amendment to the EAR Entity List to add China Aviation Development Harbin Bearing Co., Ltd. — an AVIC subsidiary and specialist precision-bearing manufacturer — that was included in the preamble of the June 14, 2023 final rule (88 FR 38739) but inadvertently omitted from the regulatory text. The entity was designated for acquiring and attempting to acquire US-origin items in support of China's military modernization, including hypersonic weapons development, air-to-air missiles, and weapon lifecycle management using Western software. All EAR-subject items require a licence with a presumption of denial; retroactive effective date of June 16, 2023.

BIS published a final rule adding 43 entities under 50 entries to the EAR Entity List and removing one entity (Fiber Optic Solutions, Latvia), effective June 12, 2023. The additions span ten countries — China (31 entities), UAE (5), Pakistan (4), South Africa (3), UK (2), and one each in Kenya, Laos, Malaysia, Singapore, and Thailand — targeting four principal threat clusters: China's military modernization and hypersonic-weapons supply chain, an international network of flight-training academies (TFASA and affiliates) providing Western pilot training to Chinese military personnel, Pakistan-linked procurement for unsafeguarded ballistic-missile programs, and UAE/South Africa-based dual-use diversion networks. All listed entities require a BIS licence, with most subject to a presumption of denial.

The Bureau of Industry and Security (BIS) added 37 entities under 38 entries to the Entity List, effective March 2, 2023, spanning six destinations: China (28), Pakistan (4), Burma (3), Russia (1), Belarus (1), and Taiwan (1). The China tranche — the largest — targets entities supporting the People's Liberation Army's military modernization, including BGI Research and Forensic Genomics International (genomic surveillance/data risk), Inspur Group Co. Ltd. (cloud servers supplied to Chinese military), and Loongson Technology (domestic CPU developer). Three Burmese entities, including the Ministry of Transport and Communications, are designated for providing surveillance equipment enabling the military junta's tracking and targeting of civilians. Pakistani entities Abdul Razaq Asim, Add-On Technology, and Dynamic Engineers are added for contributing to Pakistan's ballistic missile programs; Russian DMT Electronics and Belarusian DMT Trading LLC for export-control evasion. All listed entities are subject to a license requirement for all items subject to the EAR, with the review policy being presumption of denial for the majority of Chinese entries.

The Bureau of Industry and Security (BIS) added 76 Russian entities to the Entity List effective February 24, 2023, spanning three rationale categories: (1) biometric surveillance technology enabling Russian filtration operations in occupied Ukraine; (2) illicit acquisition of U.S.-origin controlled items; and (3) the Russian military-industrial complex encompassing missiles, aviation, shipbuilding, semiconductors, telecom, and defense electronics. All 76 entities are subject to a license requirement for all EAR-subject items with a presumption of denial; 66 entities receive footnote-3 designation as Russian military end-users, subjecting them to the Russia/Belarus Military End-User Foreign Direct Product Rule under §734.9(g). Four existing Entity List entries were simultaneously revised with additional aliases and tightened to a policy of denial. Notable designations include KAMAZ, the Skolkovo Foundation, Skoltech, Ilyushin Aviation Complex, and the State Missile Center Named After Akademika V.P. Makeyev.

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 Bureau of Industry and Security added 57 entities under 57 entries to the Entity List, effective September 30, 2022, in direct response to Russia's ongoing invasion of Ukraine and its illegal annexation of Ukrainian regions. Of the 57 entities, 56 are listed under Russia and one (Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard) under the Crimea Region of Ukraine. The additions span aviation repair and overhaul facilities, aerospace R&D institutes, naval propulsion, ballistic-missile producers, advanced-materials and quantum science institutes, and the federal metrology agency; 50 of the 57 receive footnote 3 designations as Russian military end users, subjecting them to the Russia/Belarus-Military End User Foreign Direct Product Rule. All are added with a license review policy of denial for all EAR-subject items except food and medicine designated EAR99.

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.