On December 23, 2020, the Commerce Department amended the EAR to add the recently released Military End-Users list, which initially includes entities in China and Russia but will also include entities in Venezuela in the future. This final rule will add 102 military end users to the MEU List consisting of 57 in China and 45 in Russia. However, the establishment of the MEU List does not imply that other parties, not included on the list, are not subject to the military end-use and military end user controls under the EAR. Exports of items with certain classifications previously able to be exported No License Required, will now require a license which will be reviewed with a presumption of denial. Before exporting to Russia, China, or Venezuela you must review the Military End-User list, along with the list of classifications which are restricted. The list of classifications can be found in Supplement No. 2 To Part 744 – List Of Items Subject To The Military End-Use Or End User License Requirement Of §744.21. https://www.bis.doc.gov/index.php/documents/regulations-docs/2343-part-744-control-policy-end-user-and-end-use-based-2/file
Please review the final rule in the Federal Register: https://www.govinfo.gov/content/pkg/FR-2020-12-23/pdf/2020-28052.pdf
A final rule has also been published that removes Hong Kong as a separate destination in the EAR. Hong Kong is now considered indistinguishable from China as it pertains to export regulations.
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