News & Analysis as of

Dual Use Goods

Pillsbury Winthrop Shaw Pittman LLP

China Suspends Export Controls on Certain Critical Minerals and Related Items

On October 9, 2025, China’s Ministry of Commerce (MOFCOM and General Administration of Customs (GAC) published a set of announcements (Nos. 55 to 58 and 61, 62) with a series of export control measures. These include export...more

Hughes Hubbard & Reed LLP

EU Sanctions in a Snap: Developments In Sanctions - October 2025

Hughes Hubbard’s “Sanctions in a Snap” is intended to provide a clear and concise summary of recent and important developments from the European Union (EU) and its member states. We hope you find it helpful in assessing EU...more

Jones Day

China Imposes Extraterritorial Export Control Measures Over Rare Earth Items

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On October 9, 2025, China's Ministry of Commerce ("MOFCOM") unveiled several new measures tightening export controls of sensitive materials and technologies. Most notably, the new measures assert extraterritorial controls on...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Protecting Defense Technology Innovations

Defense contracting is entering an era characterized by more competition, a faster pace of innovation, and dual-use technology. Defense contractors that are succeeding in this new environment are pursuing patent protection...more

Clark Hill PLC

China expands export controls on rare earths, magnets, and high-tech materials: What companies need to know

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On Oct. 9, China’s Ministry of Commerce (“MOFCOM”) issued new export-control notices tightening restrictions on the export of rare-earth materials, magnet technologies, superhard materials (synthetic diamonds), and...more

Herbert Smith Freehills Kramer

China Imposes Export Controls on Lithium-batteries and Artificial Graphite Anode Materials

The decision means exporters will need a licence while new restrictions on rare earth items are also implemented - On 9 October 2025, China's Ministry of Commerce (MOFCOM) and the General Administration of Customs (Customs)...more

American Conference Institute (ACI)

[Event] 7th Conference on China Trade Controls - November 6th - 7th, Arlington, VA

It is crucial for trade compliance teams to stay informed and stay agile as trade negotiations between the U.S. and China continue and new risks emerge. ACI's 7th Conference on China Trade Controls is the only trade...more

Wiley Rein LLP

ATF Allows Importation of Dual-Use Firearm Barrels, Irrespective of Previous Status or Configuration

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The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has issued Ruling 2025-1, which loosens ATF’s policy with respect to the importation of firearm barrels. Specifically, the agency will now allow the importation of...more

The Volkov Law Group

Israeli Freight Forwarder Sentenced to Two Years in Prison for Violating U.S. Export Controls on Aircraft Components to Russia

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The recent sentencing of Israeli freight forwarder Gal Haimovich to two years in federal prison for violations of U.S. export controls serves as a striking example of the aggressive enforcement posture adopted by U.S....more

Morrison & Foerster LLP

China’s New Export Control Framework: Key Changes for Dual-Use Items

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On December 1, 2024, two key components of China’s export control regime took effect: the “Regulations on Export Control of Dual-Use Items” (“DIR”) and the “Export Control List of Dual-Use Items” (the “Dual-Use Items List”)....more

Buchalter

The U.S. Finalizes Outbound Investment Restrictions on Technology Development

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Precedent-Setting Investment Restrictions – On January 2, 2025, the U.S. will start restricting foreign investments by U.S. persons in certain national security technologies. The Outbound Investment Rule and associated...more

K&L Gates LLP

Adapting to Change: Understanding China's Updated Export Control Framework for Dual-Use Items

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Since its implementation on 1 December 2020, the Export Control Law of the People’s Republic of China (the Export Control Law), has established a comprehensive framework for China’s export control system. To further...more

Baker Botts L.L.P.

China Bans Exports to U.S. of Critical Minerals Used in High Tech “Dual-Use” Materials

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On December 3, 2024, the Chinese Ministry of Commerce announced strict export restrictions on “dual-use” technologies. Dual-use technologies are those that are developed for civilian markets but also have military utility or...more

Akin Gump Strauss Hauer & Feld LLP

Guidelines on the Export of Cyber-surveillance Items Under Article 5 of Regulation 2021-821

In 2021, the European Union (EU) updated the EU Dual-Use Regulation, setting unified standards for EU member states to control exports of dual-use items. A key addition in Regulation (EU) 2021/821 is Article 5’s “catch-all...more

American Conference Institute (ACI)

The Future of Plurilateral Agreements: Compliance Considerations

The evolution of critical and emerging technologies continues to affect how the United States and its international allies and partners uniformly protect against national security threats. For industry, the strengthening of...more

Pillsbury Winthrop Shaw Pittman LLP

Trump 2.0 Administration: Anticipated Impacts on International Trade, Sanctions and Economic Policy

Broad Tariff Increases Could Reshape Global Trade: The aggressive use of tariffs could create significant trade disruptions for businesses dependent on global supply chains, and pair novel use of authorities with existing...more

Hogan Lovells

China issues the regulations on the export control of dual use items

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On September 30, 2024, China’s State Council issued the Regulations on the Export Control of Dual-use Items (the “Regulations”), which will take effect on December 1, 2024. This marks the first time the Chinese government has...more

Orrick, Herrington & Sutcliffe LLP

China Issues Regulation on Export Control of Dual Use Items

China has issued the Regulation on Export Control of Dual-Use Items (the “Regulation”), which will take effect on December 1, 2024. The Regulation aims to provide clearer guidance for export control authorities’ law...more

Pillsbury Winthrop Shaw Pittman LLP

China Issues New Export Control Regulations on Civil-Military Dual-Use Items

The new export control regulations consolidate existing dual-use items export control regulations and aim to regulate the export of goods, technologies and services that can be used for both civilian and military purposes. ...more

Sheppard Mullin Richter & Hampton LLP

EU’s New Export Due Diligence Guidelines: Keeping Tabs on Cyber-Surveillance Technology

In 2021, the EU adopted an updated version of the EU Dual-Use Regulation, which establishes common standards for the control of dual-use item exports by EU member states. Among its new provisions, Regulation (EU) 2021/821...more

Skadden, Arps, Slate, Meagher & Flom LLP

US AI Industry Reporting for Duty: BIS Rule Would Require Quarterly Filings for ‘Dual-Use’ AI Models and Computing Clusters

On September 11, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published a proposed rule that would require U.S. persons to report certain activities related to the development or acquisition of...more

ArentFox Schiff

Wow AUKUS is for Real! Exports to Australia and UK Just Got Way Easier

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The US Government just placed Australia and the United Kingdom (UK) in nearly the same position as Canada for dual-use exports under the Export Administration Regulations (EAR) and is poised to go even further with a proposed...more

The Volkov Law Group

New BIS Rule Implementing AUKUS Effectuates Sweeping Changes to Dual Use Export Controls

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On April 19, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“IFR”) that officially codifies certain changes to the Export Administration Regulations (“EAR”)...more

White & Case LLP

New dual-use export control and outbound investment approach as part of the EU's Economic Security Strategy

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Continuing the work from the Joint Communication on a European Economic Security Strategy published in June 2023, the European Commission unveiled a comprehensive package with five proposed initiatives to strengthen the EU's...more

Hogan Lovells

Make Europe safe again – European Commission proposes more coordination on EU dual-use export controls

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The European Commission presented the European Economic Security Package ("EESP"), a toolkit to ramp-up European action in investment, trade and research in the face of rising geopolitical tensions, geo-economic fragmentation...more

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