The Bureau of Industry and Security has so far issued three general authorizations allowing importers to engage in certain transactions otherwise prohibited by a January 2025 final rule banning the importation of certain connected vehicles.
The rule (1) prohibits vehicle connectivity system hardware importers from knowingly importing certain hardware for VCS, (2) prohibits connected vehicle manufacturers from knowingly importing completed connected vehicles incorporating covered software, and (3) prohibits connected vehicle manufacturers from knowingly selling within the U.S. completed connected vehicles that incorporate covered software. These prohibitions will apply when such VCS hardware or covered software is designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of China or Russia. The rule also prohibits connected vehicle manufacturers who are persons owned by, controlled by, or subject to the jurisdiction or direction of China or Russia from knowingly selling in the U.S. completed connected vehicles that incorporate VCS hardware or covered software.
This rule will apply only to passenger vehicles (defined as those under 10,001 pounds). The prohibitions on software will take effect for model year 2027 and the prohibitions on hardware will take effect for model year 2030, or Jan. 1, 2029, for units without a model year.
Since issuing its final rule, BIS has issued three general authorizations allowing importers to engage in the following activities without being granted a specific authorization and/or submitting a declaration of conformity.
- Connected vehicle manufacturers may import completed connected vehicles that incorporate covered software or VCS hardware and that will be (1) subject to limited use for display, testing, or research, or (2) imported temporarily for purposes of repair, alteration, or sporting competition and subsequently exported within one year of importation.
- Connected vehicle manufacturers may import completed connected vehicles that incorporate covered software if the vehicles are temporarily imported exclusively to be subsequently exported to a non-U.S. market for sale, and VCS hardware importers may import such goods if they are being temporarily imported and integrated into a connected vehicle and subsequently exported to a non-U.S. market for sale.
- VCS hardware importers may import certain VCS hardware provided that both the hardware and its respective supplier(s) are listed together in an Approved Supplier Registry (which will be published later), and connected vehicle manufacturers may import or sell completed connected vehicles that incorporate covered software provided that both the software and its respective supplier(s) are listed together in the Approved Supplier Registry.
Each of these general authorizations includes recordkeeping and verification requirements, restrictions, and other provisions. Click here for the full text of these authorizations as well as a list of related FAQs.
Copyright © 2026 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.