Overview
- The final rule pauses the Affiliates Rule from November 10, 2025 through November 9, 2026, after which the suspended provisions are scheduled to snap back absent an extension.
- Under the two‑phase framework, BIS suspends all EAR changes made by the September 29 rule during the one‑year window and then reintroduces them on expiration.
- China agreed to suspend its rare‑earth export controls and to issue general licenses for rare earths, gallium, germanium, antimony, and graphite to U.S. end users and their suppliers.
- The suspension does not repeal the Affiliates Rule, which had expanded controls to entities 50% or more owned by parties on the Entity List, Military End‑User List, or specified SDN programs.
- The action resolves the earlier implementation gap by placing the suspension in the Federal Register, while advisors caution companies to treat the pause as temporary and continue compliance preparations.