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Chinese, Other Entities Added to Export Restrictions List

Monday, June 08, 2020
Sandler, Travis & Rosenberg Trade Report

Effective June 5, 33 new entities in China and elsewhere were added to the Bureau of Industry and Security’s Entity List, which lists entities restricted from receiving U.S. exports of goods controlled under the Export Administration Regulations. Nine Chinese entities are being added for their involvement in human rights violations and abuses in China’s Xinjiang Uighur Autonomous Region and 24 entities based in China, Hong Kong, and the United Kingdom are being added because they represent a significant risk of supporting procurement of items for military end-use in China.

For the nine Chinese entities, BIS is imposing a license requirement for exports of all items subject to the EAR along with license review policies of (1) case-by-case review for ECCNs 1A004.c, 1A004.d, 1A995, 1A999.a, 1D003, 2A983, 2D983, and 2E983, (2) case-by-case review for items designated as EAR99 that are described in the note to ECCN 1A995 (i.e., items for protection against chemical or biological agents that are consumer goods, packaged for retail sale or personal use, or medical products), and (3) presumption of denial for all other items subject to the EAR. This requirement applies to any transaction in which items are to be exported, reexported, or transferred (in-country) to any of these entities or in which they act as purchaser, intermediate consignee, ultimate consignee, or end-user. In addition, no license exceptions are available for exports, reexports, or transfers (in-country) to these entities.

For the other 24 entities, BIS is imposing a license requirement for exports of all items subject to the EAR and a license review policy of presumption of denial. In addition, no license exceptions are available for exports, reexports, or transfers (in-country) to these entities.

Shipments of items removed from license exception eligibility or for export or reexport without a license (NLR) as a result of these rules that were en route aboard a carrier to a port of export or reexport on June 5 pursuant to actual orders for export or reexport to a foreign destination may proceed to that destination under the previous license exception eligibility or without a license.

These rules also modify five entries under the destination of China to clarify entity names, update addresses, or make other changes.

For more information on restrictions on exports to persons on the Entity List or other lists, please contact Kristine Pirnia.

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