49 Entities Additions to BIS for Circumvention of Integrated Circuits to Russia

Oct. 11, 2023
By: Marvin E. McPherson

Bureau of Industry and Security (BIS) added 49 entities to the Export Administration Regulations (EAR). The entities under the destinations of the People’s Republic of China (China) (42), Estonia (1), Finland (1), Germany (1), India (3), Turkey (2), United Arab Emirates (1), and the United Kingdom (1) were added to the entity list for having supplied Russian consignees connected to the Russian defense sector with U.S.-origin integrated circuits after March 1, 2023. These integrated circuits are classified under Harmonized Tariff System (HTS)-6 codes 854231, 854232, 854233, and/or 854239.

The specified circuits were included in BIS’s final rule, previously discussed in BIS Issues New Russia Export Restrictions. In that rule, BIS under supplement no. 4 to part 746 added 1,224 additional HTS-6 Code entries corresponding to 1,224 types of industrial items to supplement no. 4. The items added include a variety of electronics, instruments, and advanced fibers for the reinforcement of composite materials, including carbon fibers. The complete list of 1,224 new HTS-6 Codes added to supplement no. 4. (pg. 41 – 85).

The presence of entities in places like Germany and the United Kingdom should serve as (another) reminder that the entity list needs to be checked, even when a shipment is headed to an allied country.

If you have any questions, please contact any attorney at Barnes Richardson and Colburn.