On May 16, 2019, a sweeping U.S. export control rule went into effect that will impact the U.S. tech industry, but may also create an outsized risk for non-U.S. manufacturers. The rule, issued by the U.S. Department of Commerce, Bureau of Industry and Security (BIS) adds Huawei Technologies Co., Ltd. (Huawei) and 68 of its affiliates to the Entity List. That designation effectively prohibits the export, reexport, and retransfer of all U.S.-origin “items subject to the Export Administration Regulations (EAR)” to those entities. The designation arises from a U.S. government finding that the restrictions are warranted on U.S. national security and foreign policy grounds.
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U.S. Department of Commerce
New “Beast” Rules Lessen the Export Control Burden
By: Scott Maberry, Curtis Dombek, and Cheryl Palmeri
On April 16, 2013, the U.S. Departments of State and Commerce published the first in a series of final rules, amending the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR) in accordance with President Obama’s 2009 Export Control Reform (ECR) initiative.[1] This is a significant milestone in export reform. The ECR aims to focus U.S. government efforts on controlling the export of sensitive technologies while streamlining exports of defense-related items to U.S. allies and partners around the world.
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BIS Creates a Temporary Holding Classification Number on the CCL
By: Thad McBride and Cheryl Palmeri
As part of the Obama Administration’s Export Control Reform Initiative, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) has recently revised the Export Administration Regulations (EAR) by adding a new Export Classification Control Number (ECCN) series to the Commerce Control List (CCL). The newly created ECCN series 0Y521 is a temporary holding classification for items that are subject to the EAR but are not yet identified in an existing ECCN.…
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