Overview
- Implementation is suspended globally from November 10, 2025, through November 9, 2026, after a brief effective period from September 29 to November 10, 2025, with the rule scheduled to resume on November 10, 2026.
- The pause covers affiliates of entities on the BIS Entity List and Military End User List, as well as entities subject to EAR § 744.8, reflecting a complete suspension of the expanded 50% ownership reach.
- BIS states it will continue monitoring non‑listed affiliates and retains the option to make new designations during the suspension.
- The suspension is part of a broader U.S.–China understanding that also halts one year of tariff and export‑control escalations, including a reported easing of certain U.S. fentanyl‑risk tariffs and China’s one‑year pause on some critical‑mineral controls.
- Compliance advisers urge companies—especially in semiconductors, electronics, cloud and software, and multi‑year equipment servicing—to maintain ownership screening, strengthen recordkeeping, and plan for potential licensing needs after the pause.