U.S. Changes Export Regulation Exceptions Affecting Hong Kong
July 2, 2020
Cleveland, Ohio
Effective June 30, 2020, the U.S. Bureau of Industry and Security suspended any License Exceptions for exports to Hong Kong, re-exports to Hong Kong, and transfers (in-country) within Hong Kong of items subject to the Export Administration Regulations (EAR), 15 CFR Parts 730-774, that provide differential treatment than those available to the People’s Republic of China.
Additionally, any deemed export/re-export transactions involving Hong Kong persons authorized under a License Exception eligibility prior to June 30, 2020 may continue to be authorized under such provision until August 28, 2020, after which such transactions will require a license.
Essentially, exports to Hong Kong and deemed export to Hong Kong persons are now being treated as if the export or deemed exports are to the P.R.C. or P.R.C. nationals.
If you have any questions or would like further clarification, please do not hesitate to contact Ed Patton or one our Corporate and Business group attorneys.