REMINDER: US Export Restrictions Enter Into Force Today: FULL Update and Briefing

We would like to remind you that the U.S. will from today change significant EAR provisions, restricting exports of certain goods to China, Russia, Venezuela and other countries. Formally, this is known as amendments to BIS's military end-use/end-user rule for certain exports/reexports to China, Russia, and Venezuela.

This is now in effect.

It refers to 15 CFR § 744.21 of the EAR.

We present in this blog post the latest developments, provide extensive background information for newcomers (so that everyone understands) and focus on the TOP 3 changes you need to know about what happens today.

To illustrate the challenge, please look at the practical example towards the end.

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20 FAQ Questions and answers

Late Friday, BIS issued 31 FAQs on the rule.Please refer to the FAQ document issued by BIS: Click here

Due Diligence: OBTAIN END-USE and END-USER STATEMENTS from your customers

It is essential that exporters/reexporters update and obtain end-use/end-user statements from customers.

EEI Filing starts today

  1. Effective today an EEI filing is required for ALL exports of items to China, Russia, or Venezuela listed in amended Supp. 2 to Part 744, regardless of value.

  2. Starting on Sept. 27, 2020, an EEI filing will be required for ALL exports to China, Russia, or Venezuela, regardless of value and ECCN. This requirement does not affect items classified as EAR99.

No more CIV exception

Finally, effective today license exception CIV has been removed from section 740.5 of the EAR and can no longer be used for any exports or exports.

As a result, many companies will have to obtain export/reexport licenses from BIS


Here is what we have still left to cover in this blog entry...

  1. Background

  2. What are BIS and the EAR?

  3. Military End-Use & End-User Export Controls are broadened

  4. What is a License Exception?

  5. What does CIV stand for?

  6. Changes to APR license exception

  7. A practical example of how it's getting tough under the new rules

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