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

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).

On 6 February 2025 the South African Revenue Service updated its Prohibited and Restricted Imports and Exports list to require an International Trade Administration Commission (ITAC) export permit for a broad basket of base-metal tariff headings: 72.04 (excl. 7204.21), 7404.00, 72.05, 72.06, 72.07, 72.18, 72.24 (iron/steel waste, ingots, semi-finished and granules), 74.02, 74.03, 74.05, 74.06 (unrefined/refined copper and copper powders), 76.01, 76.03, 76.04 (unwrought aluminium, powders and bars), 78.01 (unwrought lead), 79.01 (unwrought zinc) and 80.01 (unwrought tin). The same update removed the export-permit requirement from six copper sub-headings (7403.12, 7403.13, 7403.19, 7403.21, 7403.22, 7403.29) and added several machinery tariff headings (8417.10, 8417.80, 8462-series) to the import-permit list.

MOTIE brought the 35th amendment of the Public Notice on Trade of Strategic Items into force on 9 September 2024, adding 243 items (notice Annex 2-2 numbers 1160-1402) to the situational-licence list for Russia and Belarus, taking that list to 1,402 items. The added items are described as having a high likelihood of military diversion (metal-cutting machinery, machine-tool parts, optical-equipment parts, sensors). Exports of the added items are prohibited in principle from 9 September, with licence applications admitted only for contracts concluded by 8 September and case-by-case categories such as exports to Korean companies' local subsidiaries. The same release tightens administrative penalties for deliberate export-control violations.

BIS final rule (FR Doc 2024-19132, 89 FR 68539, published 27 August 2024) expanding the Russia/Belarus-Military End User (MEU) Foreign-Direct Product (FDP) rule under the Export Administration Regulations so that it also applies to transactions involving Entity List entries posing a significant diversion risk to Russia's and Belarus's defense industry or intelligence services — the rule is renamed accordingly. The rule also imposes new export, reexport, and in-country transfer controls on software for the operation of computer numerical control (CNC) machine tools destined for Russia or Belarus, and makes corrections eliminating obsolete cross- references introduced by the BIS 25 January 2024 and 18 June 2024 Russia/Belarus final rules. Effective 27 August 2024, except amendatory instruction 11 effective 16 September 2024.

BIS final rule (FR Doc 2024-13148, 89 FR 51644, RIN 0694-AJ87) expanding the Export Administration Regulations' Russia and Belarus sanctions architecture. Effective 12 June 2024 (most provisions) and 16 September 2024 (the EAR99 enterprise-software paragraph at §746.8(a)(8)), the rule introduces a new licence requirement for thirteen named categories of EAR99 enterprise software (ERP, CRM, BI, SCM, EDW, CMMS, project management, PLM, BIM, CAD, CAM, ETO) destined for Russia or Belarus; permits address-only Entity List designations to capture high-diversion addresses; adds eight Hong Kong addresses to the Entity List; and refines the Russia/Belarus Industry Sector Sanctions and Foreign Direct Product (FDP) rule. Released the day before the G7 Italy summit alongside coordinated OFAC, State, and Treasury actions that together designated 300+ persons and entities.

On 5 April 2024 Japan's Cabinet adopted an amendment to the Export Trade Control Order, following a 1 March 2024 Cabinet understanding, extending the export prohibition on goods that strengthen Russia's industrial base. The additional goods span parts of HS chapters 27 (mineral fuels and oils), 28 (inorganic chemicals), 39, 73, 81 (tungsten powder, molybdenum, cobalt, zirconium, rhenium), 82, 84, 85 (including lithium-ion and nickel-metal-hydride batteries), 89 and 90, with the specific goods fixed by ministerial ordinance and notices issued on 10 April. The export ban applies from 17 April 2024. A separate METI notice bans imports of non-industrial diamonds of Russian origin from 10 May 2024, regardless of port of shipment.

MOTIE brought the 33rd amendment of the Public Notice on Trade of Strategic Items into force on 24 February 2024 (announced 20 February 2024), adding 682 items to the Russia/Belarus situational-licence (상황허가) list, taking that list to 1,159 items. The added items span construction machinery, secondary batteries, machine tools and aircraft components judged to have high military-diversion potential. Situational- licence items are prohibited from export in principle from the effective date, with narrow exceptions such as pre-existing contracts and case-by- case review categories.

The Bureau of Industry and Security (BIS) removed four Chinese entities from the Unverified List (UVL) effective 15 December 2023, after successfully verifying their bona fides pursuant to § 744.15(c)(2) of the Export Administration Regulations (EAR). The four entities span oscillator electronics (Chengde), heavy industrial machinery (Erzhong), laser systems (Ningbo), and new-energy manufacturing (Xinjiang). Removal restores eligibility for EAR license exceptions and eliminates the requirement for a signed UVL Statement before US exporters ship EAR-subject items to these parties.

MOTIE finalised the 31st amendment of the Public Notice on Trade of Strategic Items on 24 April 2023, effective 28 April 2023, adding 741 items to the Russia/Belarus situational-licence (상황허가) list. The added items span industrial machinery, petroleum and gas refining equipment, steel, chemicals, automotive goods and quantum computers judged to have high military-diversion potential. MOTIE stated the amendment brings Korea's export-control coverage of Russia/Belarus closer to that of the US, EU and Japan, incorporating 2022 international export-control-regime agreements and reflecting the US's 2nd-6th Russia sanctions rounds and a substantial part of the EU's measures.

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 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.

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.

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.

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.