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

On 10 October 2025 Vietnam's Government issued Decree No. 259/2025/NĐ-CP, establishing the country's first comprehensive statutory framework for strategic trade control — covering the export, temporary import for re-export, transshipment, transit, and cross-border trade of strategic goods defined as: (a) WMD-related items, (b) conventional weapons, and (c) dual-use goods spanning nuclear, electronics, telecommunications, sensors, aviation, maritime, aerospace, biochemical, metals, and chemical categories. The decree creates a Ministry of Industry and Trade (MoIT) licensing regime with an ICP (Internal Compliance Programme) fast-track for certified exporters of two or more years' standing, and includes catch-all provisions requiring licensing even for unlisted goods where WMD end-use or a designated end-user is suspected. Structurally, the decree represents Vietnam's transition from ad-hoc export-management provisions under legacy Decree 69/2018/NĐ-CP to a unified strategic-trade-control architecture analytically aligned with the Wassenaar Arrangement, Australia Group, Nuclear Suppliers Group, and MTCR control-list architecture. It positions Vietnam as a compliant strategic-goods manufacturing hub within the US-led friend-shoring supply chain, directly preceding the US announcement in February 2026 of Vietnam's removal from EAR Country Groups D:1–D:3.

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.

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 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 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 Defence Trade Controls Amendment Act 2024 (C2024A00021) received Royal Assent on 8 April 2024 and created three new criminal offences in the Defence Trade Controls Act 2012: section 10A (supply of Defence and Strategic Goods List technology in Australia to a non-exempt foreign person); section 10B (secondary supply of DSGL Part 1 Munitions or Part 2 Dual-Use Sensitive/Very Sensitive goods or technology outside Australia when originally exported from Australia); and section 10C (provision of DSGL Part 1 services to foreign nationals outside Australia). All three offences carry maximum penalties of 10 years imprisonment or 2,500 penalty units (~A$782,500), or both. The offence framework commenced 1 September 2024 with a six-month compliance-transition period; criminal liability attached from 1 March 2025. The Act also codifies AUKUS-partnership exemptions, carving out supplies to and from citizens and permanent residents of the United Kingdom and United States, underpinning the licence-free trilateral technology-transfer environment sought under AUKUS Pillar 2.

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 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.

The Bureau of Industry and Security (BIS) added 10 entities under 13 destination entries to the Entity List, effective February 24, 2023. The additions span three groups: (1) five Chinese entities operating in the commercial satellite and dual-use space sector — most notably Spacety Co., Ltd. and China HEAD Aerospace Technology Co., both suspected of supplying satellite imagery and space technology in support of the Russian military in Ukraine; (2) two Canadian procurement intermediaries (CPUNTO Inc. and Electronic Network Inc.) facilitating illicit acquisition of US-origin controlled items; and (3) three Russian defense-industrial procurement companies supplying the Russian military. All listed entities are subject to a license requirement for all EAR-subject items with a policy of denial, except EAR99 food and medicine which receive case-by-case review.

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 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).

Canada amended the Special Economic Measures (Belarus) Regulations via SOR/2022-167, registered and in force 25 June 2022, adding four new schedules targeting Belarus over its support for Russia's invasion of Ukraine. Schedule 3 bans export of advanced technologies (quantum computers, advanced manufacturing and cryogenic equipment); Schedule 4 bans export of luxury goods (Part 1) and import of luxury goods from Belarus (Part 2); Schedule 5 bans export of goods usable in weapons manufacturing, including raw materials such as tungsten, aluminium and titanium, engines, industrial machinery, vehicles, aircraft and maritime vessels. The same instrument added 13 Belarusian officials and 2 state entities to the asset-freeze list.

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 3 February 2022, the Bureau of Industry and Security published a final rule (87 FR 6231, FR Doc 2022-02302) consolidating all existing Foreign Direct Product (FDP) rules from scattered locations in EAR Parts 736 and 744 into a single new section, 15 CFR §734.9, under Part 734 (Scope of the EAR). The rule made no substantive changes to existing controls — it reorganised four pre-existing FDP rules (National Security, 9x515, 600 Series, and Entity List) into a clean §734.9(b)–(e) architecture, clarified the definition of "major component" at §734.9(a), and corrected a drafting ambiguity that had obscured the U.S.-origin technology trigger for three of the four rules. The newly created §734.9 structure became the vehicle used by BIS to add the Russia/Belarus FDP rule (§734.9(f)) just 21 days later, on 24 February 2022.

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.).

The Bureau of Industry and Security (BIS) amended 15 CFR Part 742 to revise the license review policy for items controlled for National Security (NS) reasons destined to the People's Republic of China, the Russian Federation, and Venezuela. The rule shifts the evaluation standard from assessing contributions to "military capabilities" to whether the export will make a "material contribution to the development, production, maintenance, repair, or operation of weapons systems" of those countries. Venezuela is added to the pre-existing China/Russia NS review framework, and BIS codifies a presumption of approval for civil end-uses and a presumption of denial for weapons-system contributions, supplemented by an illustrative list of review factors to guide license applications.

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.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding sixty entities under sixty-one entries to the Entity List (Supplement No. 4 to Part 744), effective August 27, 2020. The designated entities, spanning China, Hong Kong, France, Indonesia, Malaysia, Oman, Pakistan, Russia, Switzerland, and the UAE, were found to be acting contrary to US national security or foreign policy interests. The rule also revised five existing entries under Canada, Germany, Hong Kong, Iran, and the UAE.