The Bureau of Industry and Security has issued separate final rules (available here and here) that, effective Jan. 16, add a total of 25 entities in China and two in Singapore to the Entity List for various reasons, including advancing China’s military modernization and development of advanced weapons systems.
For all of these entities BIS is imposing a license requirement for exports, reexports, and transfers (in-country) of all items subject to the Export Administration Regulations and a license application review policy of presumption of denial. Some of these entities are being added to the Entity List with a designation meaning that “items subject to the EAR” includes foreign-produced items.
BIS is also removing three entities within one entry on the Entity List for India to reduce barriers to advanced nuclear energy cooperation, including joint research and development and science and technology cooperation.
Shipments of items removed from eligibility for a license exception or for export, reexport, or transfer (in-country) without a license (NLR) as a result of these rules that were en route aboard a carrier to a port of export, reexport, or transfer on Jan. 16 pursuant to actual orders for export, reexport, or transfer to or within a foreign destination may proceed to that destination under the previous eligibility before Feb. 18. Any such items not actually exported, reexported, or transferred before midnight on Feb. 18 will require a license in accordance with this rule.
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