The United States Revises Export Control Regulations: Strengthened Supervision of Specific Cameras and Components

On February 23, 2024, the Bureau of Industry and Security (BIS) of the US Department of Commerce issued an important amendment to Part 744 of the US Export Administration Regulations (EAR). This amendment mainly concerns the license requirements for specific cameras, systems, and related components. At the same time, a new Export Control Classification Number (ECCN) 6A293 was introduced to strengthen the control of certain specific cameras. These changes aim to adapt to technological and commercial developments and strengthen the strategic cooperative relationship between the US and its allies.

Amendment to the Current Camera License Requirements
BIS has adjusted Article 744.9 (a)(1) of the EAR. The main changes include updates to the export, re - export, and transfer (domestically) restrictions on certain cameras, systems, or related components. Importantly, this amendment relaxes the restrictions on specific cameras, systems, and related components destined for countries in Country Group A:1. Based on the conclusion drawn by the US from license data analysis, that is, when these items are destined for countries within Country Group A:1, they do not pose a risk to US national security. This indicates that the US government intends to deploy resources more effectively in reviewing transactions that may pose a higher risk.

Newly added ECCN 6A293
The newly introduced ECCN 6A293 is to increase the control of specific cameras that have not been identified as ECCN 6A003 or 6A203. This is a temporary control classification, and BIS is seeking to implement these control measures through multilateral agreements. The newly added ECCN 6A293 will allow the implementation of new control measures for specific cameras with proliferation uses during the period of seeking multilateral agreements. Except for Russia, Belarus and China, cameras subject to this new ECCN can be exported to NSG participating countries without a license.

This amendment means that enterprises involved in specific cameras, systems, and related components will face new export control requirements. For enterprises whose products are classified under the new ECCN 6A293, they must comply with the new license requirements, which may affect the enterprises export plans and business strategies.
Strategy Recommendations

(1) Compliance Review:Enterprises should conduct a thorough compliance review of their products to determine whether any products are subject to the new ECCN 6A293 control and understand the corresponding export restrictions.
(2) License Application:Enterprises affected by the new rules should promptly apply for the necessary export licenses to ensure the compliance of their business.
(3) Technical Adjustment:Enterprises may need to consider technical adjustments or product redesigns to avoid or reduce the impact of export controls.
(4) Continuous Monitoring: Given that BIS is seeking multilateral agreements, enterprises should continuously monitor relevant policy developments to adjust their response strategies in a timely manner.