Supply Chain Challenges in 2021 - BIS Military End Use/End User Rules and Customs WROs

BIS has expanded its Military End Use and End User rules under the Export Administration Regulations (EAR), with updated licensing requirements on exports, re-exports, and transfers of items intended for military end use or military end users in China, Russia or Venezuela. BIS states that the rule requires “increased diligence with respect to the evaluation of end users in China, particularly in view of China’s widespread civil-military integration.”

CBP also is targeting human rights and other abuses by Chinese companies supporting the government via Withhold Release Orders and Entity List additions. These rules create further supply chain due diligence challenges.