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

Resolution No. 1466 of 27 December 2022 approves, for 2023, the volume of export quotas for licensed goods (Annex 1), the controlled ozone-depleting substances and fluorinated gases whose export and import require a licence (Annexes 2-3), and a list of goods whose export requires a licence (Annex 5). Annex 1 sets a zero quota for hard coal and anthracite, wood fuel, natural gas of Ukrainian origin, unwrought gold and silver and precious-metal scrap, and finite quotas of 900,000 t for coking coal and 540,000 t for fuel oil. The resolution took effect on 1 January 2023 and was amended repeatedly during 2023.

Statutory Instrument 213 of 2022, gazetted 16 December 2022 by Zimbabwe's Ministry of Mines and Mining Development, banned the export of lithium-bearing ores and unbeneficiated lithium except with the written permission of the Minister. The stated rationale was to force in-country beneficiation and curb revenue lost to illegal mining and smuggling of raw ore. Refined/beneficiated lithium concentrate exports were not covered and continued under the pre-existing regime. This is the foundational instrument that Zimbabwe's later lithium-export architecture (SI 57 of 2023, the February 2026 all-raw-mineral suspension) built on top of.

The US Bureau of Industry and Security modified the existing Entity List entry for Private Military Company 'Wagner' (Russia) by adding Footnote 3, formally designating it as a Russian military end user under 15 CFR § 744.21. Two new aliases and one new Saint Petersburg address were also added, bringing total aliases to five. The existing policy of denial for all EAR-controlled items applies globally — to any export, reexport, or in-country transfer to Wagner wherever located worldwide — with a narrow case-by-case review carve-out for EAR99 food and medicine.

Indonesia banned the export of raw bauxite ore (including washed bauxite) effective 10 June 2023, extending the "hilirisasi" (downstream-isation) doctrine that previously prohibited nickel-ore exports (effective 1 January 2020) to the country's second-largest mineral export. The ban is implemented through the existing Mining Law framework (UU 3/2020 amending UU 4/2009) and operationalised via Ministry of Trade Regulation Permendag 18/2022 on Provisions for Mining-Product Exports. President Joko Widodo formally announced the bauxite-export-ban schedule on 21 December 2022, citing forecast revenue uplift from IDR 21 trillion to IDR 62 trillion (~USD 1.35bn → ~USD 3.9bn) once domestic alumina/ aluminium refining ramps.

The Bureau of Industry and Security added 36 entities — 35 in China, 1 in Japan — to the Entity List under a presumption of denial for all EAR-controlled items, effective December 16, 2022. The most consequential additions are Yangtze Memory Technologies (YMTC, simultaneously removed from the Unverified List), eight Cambricon AI-chip subsidiaries, and Shanghai Micro Electronics Equipment (SMEE), China's sole domestic lithography producer. Three existing entries were revised: CETC 13 and two affiliates gained a Footnote 3 Russian-military-end-user designation, bringing them under the Russia/Belarus Foreign Direct Product rule with a blanket denial policy.

The US Bureau of Industry and Security (BIS) removed nine Russian persons from the Unverified List (UVL) and simultaneously added them to the Entity List after the Russian government failed to facilitate end-use checks for more than 60 days — the first application of BIS's October 2022 escalation policy. All nine entities are subject to a license requirement covering all items subject to the EAR, with a policy of denial and no license exceptions available. The list spans electronics traders, state maritime infrastructure, defense R&D, microelectronics, and industrial equipment manufacturers.

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.

South Africa's Minister of Trade, Industry and Competition, acting under sections 5 and 6 of the International Trade Administration Act 71 of 2002, published Government Gazette Notices R.2801-R.2804 (Gazette No. 47627, 30 November 2022). The notices impose a temporary six-month export ban (30 November 2022 - 30 May 2023) on ferrous and non-ferrous waste and scrap metal, suspend ITAC's Price Preference System for scrap metal for the same period, and introduce new export permit requirements on semi-finished metal products and import permit requirements on furnaces and scrap-melting machinery. The measure was framed as an emergency response to copper and scrap-metal theft from public infrastructure, estimated at roughly R47 billion a year.

The US Bureau of Industry and Security imposed broad new controls on the export of advanced computing chips, chipmaking equipment, and US-person services supporting Chinese semiconductor fabrication. The October 7 2022 rule blocked supply of GPUs above set performance thresholds (initially 600 GB/s interconnect / 4800 TOPS) to China and added end-use restrictions on manufacturing tools used in advanced (≤14/16 nm logic, ≤18 nm DRAM, ≤128-layer NAND) facilities, with a foreign direct product rule extending coverage globally.

The Bureau of Industry and Security (BIS) added 31 Chinese entities — including Yangtze Memory Technologies Co., Ltd. (YMTC), China's largest NAND flash manufacturer — to the Unverified List (UVL), suspending license exceptions and requiring end-user statements for all EAR-controlled items destined to these parties. BIS simultaneously removed nine Chinese entities previously on the UVL after successfully completing end-use checks. The rule also established a new 60-day UVL-to-Entity-List escalation clock and clarified that sustained host-government obstruction of end-use checks constitutes independent grounds for Entity List designation — a structural enforcement change aimed at closing China's pattern of blocking BIS post-shipment verification visits.

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 Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 15 September 2022, adding new export-control categories covering quantum computing equipment and related technology (new licensing requirements under a near-total policy of denial), discrete chemicals and biologics including fentanyl precursors and CBW-related production equipment (new Supplement No. 6 to Part 746), and 57 EAR99 industrial items added to the industry-sector sanctions list (Supplement No. 4). Six entities were concurrently designated as Russian Military End Users (MEU), and MEU/MIEU licensing restrictions were extended worldwide (previously limited to six countries). The rule also extended the Foreign Direct Product Rule to additional categories of foreign-made items.

The U.S. Bureau of Industry and Security (BIS) added seven Chinese entities — under seven entries — to the Entity List, effective August 24, 2022, for acquiring or attempting to acquire U.S.-origin items in support of China's military modernization efforts. The entities span China's state-owned aerospace, space-technology, electronics, and control-systems research institutes. All seven entries carry a license requirement covering all items subject to the EAR, with a presumption-of-denial review policy.

The Bureau of Industry and Security (BIS) amended the Commerce Control List (CCL) under the Export Administration Regulations (EAR) to implement four emerging and foundational technology decisions agreed at the December 2021 Wassenaar Arrangement Plenary meeting, pursuant to ECRA Section 1758. The rule adds new export controls on ultra-wide bandgap semiconductor substrates (gallium oxide Ga₂O₃ and diamond), ECAD software for Gate-All- Around Field-Effect Transistor (GAAFET) integrated circuit development, and Pressure Gain Combustion (PGC) technology for advanced gas turbine engines. Controls require a licence for items destined to countries listed in the NS:1 and AT:1 columns of the Commerce Country Chart; ECAD software controls (ECCN 3D006) have a delayed compliance date of October 14, 2022.

The U.S. Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 36 entities under 41 entries to the Entity List, effective June 28, 2022. The entities — located across China, Lithuania, Pakistan, Russia, Singapore, the UAE, the United Kingdom, Uzbekistan, and Vietnam — were designated for acting contrary to U.S. national security or foreign policy interests. Key grounds include support for China's military modernization and AI-enabled surveillance programs, Pakistan-based proliferation concerns, and supply-chain facilitation for Russia amid the Ukraine invasion. The rule also revised eleven existing entries (Belarus, China, Russia, Slovakia) and corrected one entry (Pakistan).

The Bureau of Industry and Security published a final rule on 6 June 2022 (effective 2 June 2022) consolidating corrections, clarifications, and substantive amendments to the series of EAR Russia/Belarus rules issued between February and May 2022. The most significant substantive change eliminates the EAR99 food and medicine carve-out for 146 footnote-3-designated military end-user entities already on the Entity List, subjecting all items subject to the EAR — including previously exempt food and medicine — to licensing requirements with a policy of denial for the FSB, SVR, and GRU. Additional provisions clarify luxury goods value thresholds, oil refinery sector controls, and civil telecommunications license review policy, and correct cross-references in the Foreign Direct Product Rules for Russia and Belarus.

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.

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.

Canada amended the Special Economic Measures (Russia) Regulations via SOR/2022-102, registered 18 May 2022, adding Schedule 6 (luxury goods) and Schedule 7 (goods usable in weapons production/manufacturing) to the list of items prohibited for export to, and in Schedule 6's case also import from, Russia. Both schedules took effect 60 days after registration (17 July 2022). Schedule 6 covers luxury alcohol, tobacco, textiles, footwear, clothing, jewellery, kitchenware, art, and some machinery; Schedule 7 covers raw materials (including tungsten and aluminium), pumps, vehicle parts, construction equipment, watercraft, and medical/dental/surgical equipment. The regulation also added 14 individuals to the Schedule 1 asset-freeze list.

The U.S. Department of Commerce Bureau of Industry and Security (BIS) expanded export-control sanctions on Russian industry by adding 205 HTS codes (478 Schedule B numbers) to Supplement No. 4 to Part 746 of the EAR, imposing a license requirement — with a presumption of denial — for all exports, reexports, and transfers (in-country) to or within Russia of covered industrial goods. The targeted categories span wood products, boilers, industrial machinery, pumps, compressors, textile and grinding equipment, and hydraulic motors, aligning U.S. controls with EU partner lists. The rule took retroactive effect May 9, 2022, two days before Federal Register publication on May 11, 2022.

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 Bureau of Industry and Security (BIS) issued a final rule expanding license requirements under the EAR for all items on the Commerce Control List (CCL) destined for Russia and Belarus, retroactively effective April 8, 2022. The rule also removes certain license exceptions that previously allowed aircraft-related transactions involving Belarus to proceed without authorization. Issued in direct response to Russia's continued aggression in Ukraine and Belarus's role in enabling it, this measure substantially tightens the multilateral export- control perimeter first established by BIS in late February 2022.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 120 entities under 120 entries to the Entity List, effective 1 April 2022 and published in the Federal Register on 7 April 2022. All 120 entities — located in Russia and Belarus — were determined to be acting contrary to US national security or foreign policy interests in the context of Russia's further invasion of Ukraine beginning 24 February 2022. The rule imposes a presumption-of-denial policy for all EAR-subject items and prohibits all license exceptions for exports, reexports, or in-country transfers to the listed parties. Ninety-five of the 120 entities are additionally designated under Footnote 3 of the Entity List as military end users, triggering the Russian/Belarusian Military End User foreign-produced direct product rule (MEU FDP Rule), extending US extraterritorial reach to non-US items made with US-origin technology.

Canada amended the Special Economic Measures (Belarus) Regulations via SOR/2022-075, registered and in force 5 April 2022, in response to Belarus's support for Russia's invasion of Ukraine. The amendment prohibits any person in Canada and any Canadian outside Canada from providing insurance, reinsurance or underwriting services for aviation and aerospace products owned, controlled, registered to, chartered by or operated by Belarus or a Belarusian person. A new section 3.6 separately establishes export prohibitions on goods and technologies listed on a Belarus Restricted Goods and Technologies List, incorporated by reference, aligning Canada's Belarus measures with its parallel Russia export-control regime. The same instrument added nine individuals (Belarusian oligarchs and defence officials) to the Schedule 1 asset-freeze list, outside this action's scope.

On 4 April 2022 Australia's Minister for Foreign Affairs registered the Autonomous Sanctions (Export Sanctioned Goods—Russia) Amendment (No.1) Designation 2022, made under the Autonomous Sanctions Regulations 2011. It amended the existing Export Sanctioned Goods—Russia designation to add further categories of goods to the list of items whose export, supply or transfer to Russia is prohibited, extending an export-ban regime introduced in response to Russia's invasion of Ukraine. It took effect on registration.

Canada amended the Special Economic Measures (Russia) Regulations via SOR/2022-067, registered and in force 24 March 2022, establishing a new "Restricted Goods and Technologies List" and prohibiting any person in Canada, and any Canadian outside Canada, from exporting, selling, supplying or shipping any listed good or technology to Russia or to any person in Russia. The list is maintained and published separately by Global Affairs Canada and covers items with dual civilian/military applications across electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation equipment.

Australia designated aluminium ores (including bauxite), alumina and aluminium hydroxide as "export sanctioned goods" for Russia under the Autonomous Sanctions (Export Sanctioned Goods -- Russia) Designation 2022, banning their export from Australia to Russia effective 20 March 2022. Prime Minister Scott Morrison announced the measure a day earlier as part of Australia's response to the invasion of Ukraine, framing it as an attack on Russia's aluminium industry, which sourced roughly 20% of its alumina from Australian supply. Rusal, Russia's dominant aluminium producer, was identified as the primary target.

The Bureau of Industry and Security created Supplement No. 5 to 15 CFR Part 746, establishing a new licensing requirement for the export, reexport, or in-country transfer of luxury goods to Russia, Belarus, and to Russian or Belarusian oligarchs and malign actors anywhere in the world, effective 11 March 2022. Covered goods span over 570 HTS-6 line items across categories including spirits and tobacco (above de minimis thresholds), clothing and leather goods (>$1,000 per item), jewelry and precious gemstones, watches (>$100), vehicles (>$25,000), seafood/caviar (>$100), art and antiques, and recreational vessels. The rule targets both bulk commercial exports to Russia and Belarus and personal luxury procurement by designated oligarchs worldwide, with a policy of denial for all such licence applications.

The UK government announced on 15 March 2022 that it would ban the export of high-end luxury goods to Russia in response to the invasion of Ukraine. The measure was implemented via new regulation 46B of the Russia (Sanctions) (EU Exit) Regulations 2019, inserted by the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 (SI 2022/452), which was made on 13 April 2022 and came into force at 5pm on 14 April 2022. Regulation 46B prohibits the export, supply, or making available of luxury goods to, or for use in, Russia, covering goods with a sales price over £250 (excluding VAT) and vehicles over £42,000, spanning high-end fashion, works of art, jewellery, and vehicles, subject to licensing exceptions in Part 7.

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.

Effective 3 March 2022 (retroactive to five days before Federal Register publication), the US Bureau of Industry and Security (BIS) expanded Russian Industry Sector Sanctions under the Export Administration Regulations (EAR) by adding a new license requirement and denial policy for oil refinery equipment destined for or within Russia. The rule creates 15 CFR § 746.5(a)(1)(ii) and a new Supplement No. 4 to Part 746 enumerating approximately 20 categories of refining equipment — from crude distillation units and catalytic crackers to hydrocracking reactors and sulphur recovery units. Applications are subject to a policy of denial, with a narrow health-and-safety exception reviewed case by case. The stated rationale is to limit Russia's ability to generate oil-derived government revenues used to finance its military operations in Ukraine.

On 6 March 2022, the South Korean government determined that Belarus had materially supported Russia's invasion of Ukraine and announced it would extend the export-control measures already applied to Russia to Belarus as well. Effective 7 March 2022, Korea designated two Belarusian entities (Belarus's Ministry of Defence and a second entity) to its "parties of concern" list, triggering a case-by-case licensing requirement for strategic items under Korea's multilateral export-control regime, and tightened review of non-strategic dual-use items destined for Belarus.

Effective 2 March 2022, the US Bureau of Industry and Security (BIS) extended to Belarus the same sweeping EAR sanctions imposed on Russia following Russia's full-scale invasion of Ukraine on 24 February 2022. The rule adds Commerce Control List (CCL)-based license requirements for Belarus with a policy of denial across virtually all categories, extends both the Russia Foreign Direct Product (FDP) rule and the Russia Military End User (MEU) FDP rule to cover Belarus and Belarusian military end users, and aligns Belarus with Russia's license review policy. The action was triggered by Belarus's active enablement of the Russian military operation from its territory.

On 28 February 2022, South Korea's government condemned Russia's invasion of Ukraine and announced it would strengthen export control review to block strategic items -- microelectronics, telecommunications equipment, sensors, navigation equipment, avionics, marine equipment, and aircraft components -- from reaching Russia. The statement also committed Korea to joining the exclusion of designated Russian banks from the SWIFT international payments system, with implementation details to follow through interagency consultation, alongside plans to release strategic petroleum reserves and divert LNG cargoes to Europe.

On 25 February 2022, the day after Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Regulation (EU) 2022/328, amending Regulation (EU) No 833/2014. It prohibits the sale, supply, transfer or export of dual-use goods and technology to any person, entity or body in Russia, or for military use or military end-users there, and extends to goods and technology suited for use in the oil refining industry and for the aviation and space industry, alongside a ban on related technical assistance, brokering, financing and insurance/maintenance services. The Regulation entered into force on the day after its Official Journal publication (OJ L 49, 25.2.2022), i.e. 26 February 2022.

Effective 24 February 2022 — the date of Russia's full-scale invasion of Ukraine — the US Bureau of Industry and Security (BIS) published an interim final rule (87 FR 12226, FR Doc 2022-04300) adding sweeping new export license requirements under a new § 746.8 of the Export Administration Regulations (EAR). The rule requires a licence for any item in CCL Categories 3–9 (electronics, computers, telecommunications, sensors, lasers, navigation/avionics, marine, aerospace, propulsion) exported, reexported, or transferred to Russia, with a review policy of denial. Two new Russia-specific Foreign Direct Product (FDP) rules extend US jurisdiction to foreign-manufactured goods: the Russia FDP Rule (§ 734.9(f)) covers all foreign-made items using US technology/equipment destined for Russia, and the Russia-MEU FDP Rule (§ 734.9(g)) covers items destined to 47 designated military-end-user (MEU) entities with no licence exceptions available. All three restrictions carry a presumption of denial, making this the most sweeping peacetime expansion of the EAR since its modern codification.

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 Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) on 8 February 2022 to add 33 persons — all based in China — to the Unverified List (UVL) under EAR §744.15(c), on the basis that BIS could not satisfactorily complete end-use checks for these entities for reasons outside US Government control. Placement on the UVL bars exporters from using any EAR license exception when shipping controlled items to listed parties and requires exporters to obtain a certified UVL Statement from the entity or secure a BIS export licence. Sectors represented include semiconductor manufacturing equipment, optoelectronics, UAVs, specialty chemicals, and biotechnology.