Decoding what changes for your exports — and making it actionable.
On 10 November 2026 two suspensions end on the same day. On the American side, the Bureau of Industry and Security's Affiliates Rule again extends licensing to subsidiaries owned fifty per cent or more by a listed entity: a counterparty that needs no licence today may cease to be licence-free — not for what it does, but for who owns it.
On the Chinese side, MOFCOM announcements 55 to 58, 61 and 62 take effect again. Announcement 61 would place the Chinese licence on the European operator who re-exports a product containing Chinese rare earths above 0.1 % of value — a threshold crossed, in an actuator or a generator, long before anyone thinks to check.
Drawn from the 16 September 2026 webinar of the Occitanie committee of the French Foreign Trade Advisors, this analysis compares the four regimes — American, Chinese, European, French — not by their jurisdictional hook but by their effectiveness, and identifies the two workstreams to open now: knowing who owns your counterparties, and knowing which part numbers contain Chinese rare earths. Four video chapters accompany the article.
General information, not legal advice. Read the full analysis → · Follow my insights on LinkedIn →
A recent order by the US Bureau of Industry and Security (BIS) against a major European industrial group is a reminder of an underestimated reality: a good classified EAR99 — deemed low-sensitivity — is not necessarily free to export.
At issue, the Foreign-Produced Direct Product Rule: components and software produced outside the US but derived from US technology were treated as subject to the EAR and barred from delivery to an Entity List party without authorisation.
Three lessons: an EAR99 classification does not excuse analysing destination and end-user; extraterritorial reach hits products made in Europe; a compliance programme combining contamination analysis and screening is the best protection.
General information, not legal advice. Follow my insights on LinkedIn →
The tightening of Chinese export controls on rare earths puts many sectors — automotive, defence, aerospace, electronics — under strain. Permanent magnets, ubiquitous in motors, sensors and actuators, depend on them directly.
The risk is not only commercial: production continuity itself can be affected by a foreign licensing regime, with delays and uncertainties hard to anticipate.
The response is a fine-grained exposure mapping: identify critical components, suppliers and possible substitutions, then secure supplies contractually.
General information, not legal advice. Follow my insights on LinkedIn →
Export controls are spontaneously associated with physical goods. Yet one of the most common risks is intangible: giving an engineer abroad access to controlled technology, uploading sensitive files to a cloud or demoing software can constitute an export.
With the spread of SaaS, remote work and AI platforms, these transfers multiply, often unknown to the teams and sometimes within the same group.
The remedy is methodical: map controlled technologies, inventory remote accesses and cloud flows, then govern these transfers with suitable procedures and clauses.
General information, not legal advice. Follow my insights on LinkedIn →
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