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Export Restrictions Lifted on Eight Chinese Entities

Friday, June 28, 2019
Sandler, Travis & Rosenberg Trade Report

Effective June 27, the Bureau of Industry and Security has removed the following eight persons in China from the Unverified List because an end-use check verified their bona fides.

- Beijing Bayi Space LCD Materials Technology Co. Ltd.

- Hubei Flying Optical

- Sunder Tools (Changxing) Technology

- Wuhan Yifi Laser Equipment Co.

- Wuxi Hengling Technology Co. Ltd.

- Xiaman Sanan Optoelectronics

- Zhejiang Xizi Aviation

- Zolix Instruments Co.

This rule lifts the suspension of license exceptions for exports, reexports, and transfers (in-country) involving these persons and eliminates the requirement for exporters, reexporters, and transferors of goods subject to the Export Administration Regulations but not requiring a license to these persons to obtain (and keep a record of) a UVL statement from them before proceeding with the transaction.

The UVL contains the names and addresses of foreign persons who are or have been parties to a transaction involving the export, reexport, or transfer (in-country) of items subject to the EAR whose bona fides (i.e., legitimacy and reliability relating to the end-use and end-user of items subject to the EAR) BIS has been unable to verify through an end-use check; e.g., the check could not be completed satisfactorily for reasons outside the U.S. government’s control, or during a check a recipient of items subject to the EAR was unable to produce them for visual inspection or provide sufficient documentation or other evidence to confirm their disposition. BIS may place persons on the UVL when there is insufficient evidence to place them on the Entity List.

For more information on restrictions on exports to persons on the Unverified List or other lists, please contact Kristine Pirnia at (202) 730-4964.

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