High-tech exports to China face new restrictions

Overview

The Bureau of Industry and Security (BIS) in the US Department of Commerce on April 28 published two Final Rules to the Export Administration Regulations (EAR) that change licensing and reporting requirements as they relate to exports of dual-use commodities to China.

The takeaway

Global companies — especially those with a significant portion of their supply chain or customer base in China — should analyze how elimination of the CIV license exception and modification of rules pertaining to Chinese military end-users could affect their ability to manufacture and ship products, including components and finished goods. 

Companies may wish to consider increasing their China-focused compliance efforts to address these and additional forthcoming regulations. Understanding US national security and foreign policy concerns regarding China will further help companies anticipate and tailor their compliance programs to meet these challenges.