BIS changed the license review policy from presumption of denial to case-by-case review for exports of certain advanced computing commodities to China and Macau. The policy applies to semiconductors including Nvidia H200 and AMD MI325X that are commercially available in the U.S. with Total Processing Performance (TPP) below 21,000 and total DRAM bandwidth below 6,500 GB/s. Exporters must certify sufficient U.S. supply, non-diversion of foundry capacity, recipient security procedures, and undergo independent third-party testing in the United States to verify performance specifications. Presumption of denial remains for exports to entities headquartered or with parent companies in Macau or Country Group D:5.
BIS issued a final rule revising the license review policy for advanced computing commodities exported to China. The policy changes from a presumption of denial to case-by-case review for certain advanced semiconductors including Nvidia H200 and AMD MI325X. Approval requires that exports must not reduce global semiconductor capacity available to U.S. customers, Chinese purchasers must adopt export compliance procedures including customer screening, and products must undergo independent third-party testing in the U.S. for performance and security verification. This follows a December 8, 2025 Presidential announcement allowing H200 and similar products to approved China customers.
BIS suspended for one year the Affiliates Rule that extended EAR license requirements to entities owned 50% or more by parties on the Entity List, MEU List, or SDN List. The suspension is effective November 10, 2025 through November 9, 2026, after which all Affiliates Rule provisions automatically reimpose unless BIS extends the suspension. Companies should prepare for potential snap-back compliance obligations.
Effective November 10, 2025, BIS stayed the expansion of end-user controls for affiliates of certain listed entities for one year. The provisions will be reimposed on November 10, 2026. The rule applies to amendments to 15 CFR parts 732, 734, 736, 744, and 748.
BIS added 29 entries (26 entities and 3 addresses) located in China, Hong Kong, Turkey, and the U.A.E. to the Entity List for diverting U.S. origin commodities to Iran for use in unmanned aircraft systems (UAS/UAVs). License requirement applies for all items subject to the EAR.
BIS issued a final rule revising firearms export license requirements under the EAR. The rule includes provisions for Electronic Export Information (EEI) filing in the Automated Export System (AES), enabling BIS to fulfill conventional arms reporting requirements without separate submissions from exporters. The changes include paragraph restructuring, clarifying edits, and conforming changes related to new ECCNs added by the Firearms Interim Final Rule, improving regulatory clarity for firearms exporters.
BIS expanded end-user controls to automatically extend Entity List, MEU List, and SDN List license requirements to non-U.S. entities owned 50% or more by listed parties. The 'Affiliates Rule' significantly expands the scope of restricted parties beyond explicitly named entities. IMPORTANT: This rule was suspended for one year effective November 10, 2025, with automatic snap-back scheduled for November 10, 2026.
BIS issued a final rule adding new entries to the Entity List and making revisions to existing entries. Entity List designations impose license requirements on exports, reexports, and transfers of items subject to the EAR to listed entities. This action is separate from the October 9, 2025 Entity List additions targeting diversion to Iran. Compliance teams must update screening processes to include newly added entities and review any revisions to existing entries that may affect licensing requirements.
BIS revoked Validated End-User (VEU) authorizations for certain entities in the People's Republic of China. Entities that previously benefited from VEU authorizations must now obtain individual export licenses for covered items. Exporters should verify current authorization status before proceeding with transactions.
BIS removed Intel Semiconductor (Dalian) Ltd, Samsung China Semiconductor Co. Ltd, and SK hynix Semiconductor (China) Ltd from the Validated End-User authorization list for the People's Republic of China. These entities will now require export licenses for items previously eligible for license-free export under VEU authorization.
BIS relaxed certain export controls for Syria to facilitate humanitarian assistance and support civil society activities. The changes reflect evolving U.S. policy toward Syria and create new licensing opportunities for previously restricted transactions while maintaining appropriate safeguards.
BIS relaxed EAR restrictions on exports to Syria consistent with Executive Order 14312 (June 30, 2025). Changes include revised license application review policies to be more favorable, expanded existing license exceptions to apply to Syria, added new license exceptions including for EAR99 items, and removal of General Order No. 2 from the EAR.
BIS announced the rescission of the Framework for Artificial Intelligence Diffusion on May 13, 2025, two days before its scheduled effective date of May 15, 2025. The Framework, issued as an interim final rule on January 15, 2025, would have established new worldwide licensing requirements for advanced semiconductors and advanced computing commodities under the EAR. The rescission removes the planned tiered country licensing framework and associated compliance obligations for AI chip exports. Exporters should monitor for potential replacement guidance or new rulemaking from BIS.
BIS implemented additional due diligence measures for advanced computing integrated circuits. The rule includes new Supplement Nos. 6 and 7 to Part 740 with lists of approved IC designers and approved OSAT companies, reporting requirements for front-end fabricators producing applicable advanced logic ICs for authorized IC designers, and application processes for additions to these lists.
BIS implemented export controls on certain laboratory equipment and related technology to address dual-use concerns about biotechnology. The rule adds new controls on items that could be used for biological weapons development or other nefarious purposes while balancing legitimate scientific and commercial applications.
BIS implemented additional due diligence measures for advanced computing integrated circuits, including new reporting requirements for front-end fabricators producing applicable advanced logic ICs. The rule establishes approved IC designer and approved OSAT company lists, application processes for additions to these lists, and clarifies the scope of ECCN 3A090.a.
BIS implemented controls on certain laboratory equipment and related technology to address dual-use concerns. The rule adds new ECCNs with license requirements and special conditions for Strategic Trade Authorization (STA). Controls target items with potential military or WMD-related applications.
BIS established the Framework for Artificial Intelligence Diffusion, implementing new export controls on advanced AI chips and model weights. The framework includes provisions for validated end-users, acceptable use policies, documentation and auditing requirements, and security requirements for entities receiving controlled AI technology. It creates tiered country treatment with different authorization levels.
BIS added foreign-produced direct product rule additions and refinements to controls for advanced computing commodities and related items. The rule expands controls on items produced abroad using U.S. technology, targeting advanced computing ICs and related technology with new FDP rule provisions.