The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule on September 30, 2025, rescinding the 2024 interim final rule (“Firearms IFR”) under the Export Administration Regulations (“EAR”) that had imposed new export license requirements and restrictions on firearms, ammunition, and related items. The new rule restores export controls for these items to their pre-May 2024 status, with the exception of maintaining certain new Export Control Classification Numbers (“ECCNs”). The action is intended to reduce regulatory burdens on U.S. firearms exporters while maintaining appropriate controls to protect national security and foreign policy interests.
Background
BIS issued the Firearms IFR on April 30, 2024, tightening controls on commercial firearms, ammunition, and related items under the EAR. It created four new ECCNs for semi-automatic rifles, pistols, shotguns, and certain parts (0A506-0A509) on the Commerce Control List (“CCL”). It also applied broad crime-control licensing worldwide, shortened license validity to one year, curtailed certain license exceptions, and adopted presumptions of denial for non-government end users in 36 high-risk destinations.
The Firearms IFR followed a 2023 licensing pause and policy review that identified significant diversion and misuse of U.S.-origin guns abroad. BIS used the Firearms IFR to act swiftly while soliciting public comment on further refinements.
New Developments
1. Rescission of the Firearms IFR and Restoration of Prior Controls
The final rule eliminates the majority of new restrictions and requirements imposed by the Firearms IFR, including more stringent license application and review policies, additional documentation requirements, and the reduction of license validity periods.
Export controls for firearms and related items revert to the framework in place at the end of the first Trump administration, prior to May 30, 2024.
The rule maintains four ECCNs (0A506, 0A507, 0A508, 0A509) on the CCL that the Firearms IFR introduced, which distinguish between non-automatic and semi-automatic firearms and related parts, to enhance BIS’s ability to monitor and analyze exports for diversion risks.
2. Amendments to Licensing Procedures and Documentation
The new rule makes the following changes to the firearms export licensing process:
- The rule removes the Congressional notification requirement for certain semi-automatic firearms license applications.
- The requirement to submit purchase orders and end-user passports or national identity cards for license applications is eliminated.
- The requirement to submit import certificates is limited to exports to Organization of American States member countries, and electronic equivalents are now accepted.
- The license validity period for firearms exports is restored to four years, reversing the Firearms IFR’s reduction to one year.
3. Changes to License Exceptions and Review Policies
The new rule makes the following changes to EAR license exceptions and license review policies:
- Restrictions on the use of License Exceptions for shipments of limited value and baggage (“BAG”) to certain destinations, including the Caribbean Community and Common Market (“CARICOM”) and U.S. Arms Embargoed Countries (i.e., Country Group D:5), are removed.
- The limit of three firearms per traveler under License Exception BAG is retained as a clarification of longstanding BIS policy.
- The presumption of denial for exports to non-government end users in 36 “high-risk” destinations is eliminated; instead, BIS will rely on existing national security and regional stability review policies.
- The distinction between government and non-government end users in license review policy is removed; all applications are subject to the same review standards.
4. Retention of New ECCNs
BIS is retaining the four ECCNs that the Firearms IFR introduced (0A506 for semi-automatic rifles, 0A507 for semi-automatic pistols, 0A508 for semi-automatic shotguns, and 0A509 for certain parts and accessories).
Conclusion
BIS’s final rule represents a significant rollback of the 2024 Firearms IFR, restoring a more streamlined and less burdensome export control regime for U.S. firearms, ammunition, and related items. While maintaining key controls to address diversion and national security risks, the rule seeks to respond to industry concerns and public comments by eliminating requirements that the Trump administration deemed unnecessary or overly restrictive.
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