Background

In April 2023 the State Department issued an interim final rule that removed from U.S. Munitions List category XI (and transferred to the Export Administration Regulations) certain high-energy storage capacitors that have broad commercial application, are available internationally, and do not provide a critical military or intelligence advantage.

State has now issued a final rule that, effective April 24, will remove additional such capacitors from category XI and more clearly identify the capacitors that remain in that category.

State has previously said that these changes will reduce the regulatory burden on those who export, temporarily import, retransfer, reexport, or perform brokering activities involving the subject capacitors.

For more information on this and other export control issues, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.

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