Overview
- The Commerce Department’s BIS issued a final rule on November 10 formally suspending the Affiliates Rule from November 10, 2025 through November 9, 2026, with the notice stating the pause could be extended.
- The suspended rule, first issued September 29, expanded export controls to cover entities 50 percent or more owned—directly or indirectly—by parties on the Entity List, Military End-User List, or certain SDN programs.
- As part of the arrangement, China is suspending rare‑earth export restrictions and introducing general licenses for rare earths, gallium, germanium, antimony, and graphite to U.S. end users and their suppliers.
- BIS describes a two‑phase approach that halts the rule’s EAR changes during the one‑year period and reintroduces them when the pause ends absent a further extension.
- The suspension applies to designated entities globally, and legal guidance urges companies to reinforce export‑compliance programs and prepare for a potential snap‑back under continued congressional scrutiny.