Blog Archives

BIS Adopts a “one China” policy regarding license exceptions for Hong Kong

Effective immediately (June 30, 2020) BIS has suspended use of all license exceptions for exports, re-exports or transfers within Hong Kong of items subject to the EAR unless such items are eligible for the same license exception when exported or re-exported to the Peoples Republic of China. In essense, this new ruling creates a “one China” policy with respect to that manner in which the EAR treats exports, re-exports and transfers within Hong Kong and the Peoples Republic. BIS is providing an allowance for use of Hong Kong license exceptions for shipments on dock for loading, on lighter, laden aboard an exporting or transferring carrier, or en route aboard a […]


BIS Issues Interpretive Guidance on Implementation of New Military End User Rule

The Bureau of Industry and Security (BIS) has issued new interpretive guidance and FAQs related to the new military end user rule. The guidance makes it very clear that BIS is implementing an extremely broad definition of the term military end user. Extreme due diligence will be required when exporting any product listed in Supplement 2 to Part 744 of the EAR when evaluating whether a license is required. For specific transaction evaluation please contact TSI Global Consulting at 210-757-0618.


Reminder: EEI filings for exports to China, Russia and Venezuela

The Bureau of Industry and Security has published guidance on its website reminding exporters of the new April 28th ruling that requires exporters to file the EEI through ACE for all exports when exporting products listed on the Commerce Control List (15 CFR Part 774) when exported to China, Russia and Venezuela. EEI will be required regardless of shipment value (i.e. there is no $2500 low value exemption) Effective Dates: June 29, 2020 EEI filings are required for all exports of items listed in Supplement 2 to Part 744. September 27, 2020: EEI filings for items exported to these three countries with an ECCN that is NOT listed in Supplement […]


US-Mexico-Canada Free Trade Agreement

The U.S.-Mexico-Canada (USMCA) Free Trade Agreement will be formally implemented on July 1, 2020. Links to the official USMCA regulations for each country (in English) are noted below. For commentary and/or assistance in understanding specific aspects of the USMCA, please contact our office at 210-757-0618 United States Implementing Regulations Canada Implementing Regulations Mexico Implementing Regulations