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BIS Pauses Affiliates Rule for One Year After U.S.–China Trade Deal

The pause carries global scope, leaving exporters to manage ongoing compliance risk.

Overview

  • The Bureau of Industry and Security suspended the Affiliates Rule effective November 10, 2025 through November 9, 2026.
  • The halted rule would have extended EAR license requirements to entities 50% or more owned by parties on the Entity List, the Military End User List, or subject to EAR § 744.8.
  • The suspension applies worldwide and not solely to Chinese companies, reflecting terms linked to recent U.S.–China trade negotiations.
  • BIS stated it will keep monitoring ownership-linked risks during the pause and could still designate specific entities for restrictions.
  • Companies are advised to continue ownership screening, plan for licenses or alternative structures on multi‑year deals, and prepare for potential reactivation on November 10, 2026.