Decoding what changes for your exports — and making it actionable.
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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