Commerce Department, Industry and Security Bureau Briefing 2025-09-30

Estimated reading time: 4 minutes

1. Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities

Sub: Commerce Department, Industry and Security Bureau

Content: In this interim final rule (IFR), the Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) to address diversion concerns involving entities on the Entity List and certain other restricted end users. Under this IFR, any entity that is at least 50 percent owned by one or more entities on the Entity List will itself automatically be subject to Entity List restrictions. This is a marked improvement over the current standard, which excludes all entities that are not specifically included on the Entity List, regardless of affiliation with Entity List entities. This IFR similarly applies restrictions to entities at least 50 percent owned by listed `military end users’ and certain sanctioned parties. The 50 percent ownership standard in this IFR is designed to be consistent with longstanding Department of the Treasury practice, so as to limit the additional burden on the business community.

2. Revision of Firearms License Requirements

Sub: Commerce Department, Industry and Security Bureau

Content: On April 30, 2024, the Bureau of Industry and Security (BIS) published an interim final rule (Firearms IFR) that imposed new export license requirements for firearms and related ammunition and components. American firearms manufacturers estimated that these regulatory restrictions would cost them hundreds of millions of dollars per year in lost sales. BIS, informed by public comments on the Firearms IFR, has determined that the Firearms IFR should be rescinded in its entirety–with the only exception being to maintain new Export Control Classification Numbers (ECCNs). This final rule also amends the EAR by removing the Congressional notification requirement for certain semi-automatic firearms license applications. By restoring export controls on firearms to the state they were in at the end of the first Trump Administration, BIS is advancing the Administration’s commitment to reducing regulatory burdens on industry and law-abiding firearms owners.

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