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HomeColumnsTagsEAR
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EAR

Articles about "EAR"

18 articles

18 articles (showing 12)

US EAR and China's Export Controls Reach Past Their Borders: A Guide for Japanese Exporters
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US EAR and China's Export Controls Reach Past Their Borders: A Guide for Japanese Exporters

US EAR and Chinese export controls can reach products shipped from Japan to a third country. But "one US-made part makes it subject" is a myth. This guide walks through the four ways the EAR attaches, the de minimis calculation (10% and 25%), foreign direct product rules, the 0.1% rule for Chinese rare earths and where it stands today, and a way to check your own exposure, all based on the regulations and notices themselves.

2026-10-20Ryuta Hamamoto
Does letting someone use a GPU over the network count as an export? The RASA bill, and whether Japan has the same gap
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Does letting someone use a GPU over the network count as an export? The RASA bill, and whether Japan has the same gap

You can stop the chip from leaving the country, but you cannot stop someone from using it over a network connection. This piece traces where that difference comes from, working from the text of the EAR, BIS's own advisory opinions, and the Japanese Foreign Exchange and Foreign Trade Act. It covers what the RASA bill actually says, whether Japan has the same gap, and what to check in practice.

2026-08-21Ryuta Hamamoto
When EAR99 Still Requires an Export Licence: Embargoed Destinations, End-Use and End-User Controls, and de minimis (2026 Edition)
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When EAR99 Still Requires an Export Licence: Embargoed Destinations, End-Use and End-User Controls, and de minimis (2026 Edition)

What EAR99 is, explained from the ground up: it means "subject to the EAR but not listed on the CCL" (15 CFR 734.3(c)); the three-step classification flow; and the most misunderstood part — when an EAR99 item still needs a license (embargoes, end-use, end-user), plus de minimis, FDP, and how it relates to Japan's own classification. Based on primary sources, for export-control staff.

2026-07-29Ryuta Hamamoto
US Eases EAR Controls for the UAE: What License-Free AI Chips Mean for Japanese Exporters
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US Eases EAR Controls for the UAE: What License-Free AI Chips Mean for Japanese Exporters

A practical guide to US Eases EAR Controls for the UAE: What License-Free AI Chips Mean for Japanese Exporters. Topics include EAR, BIS, UAE.

2026-07-13Ryuta Hamamoto
ECCN List and Lookup Cheat Sheet (2026): Categories, Control Codes, and Common ECCNs
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ECCN List and Lookup Cheat Sheet (2026): Categories, Control Codes, and Common ECCNs

ECCN cheat sheet: Categories 0-9, Groups A-E, what the last three digits mean, 26 common ECCNs, and manufacturer lookup pages, checked against the October 2026 eCFR.

2026-07-06Ryuta Hamamoto
BIS Advanced Computing Guidance (May 31, 2026): How the D:5 Headquarters Test Changes AI Chip and Data Center Transactions
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BIS Advanced Computing Guidance (May 31, 2026): How the D:5 Headquarters Test Changes AI Chip and Data Center Transactions

On May 31, 2026, the U.S. Bureau of Industry and Security (BIS) published a short piece of guidance on the license requirements for advanced computing items[^1].

2026-06-01Ryuta Hamamoto
What Is the BIS 50% Rule? Stay Deadline, Extension Deal, and Ownership Math
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What Is the BIS 50% Rule? Stay Deadline, Extension Deal, and Ownership Math

The BIS Affiliates Rule extends Entity List controls by ownership. The Federal Register stay still ends November 9, 2026; the US and China have announced an extension to January 10, 2027 that BIS has not yet published. How the 50% test works and how to prepare for either date.

2026-05-20Ryuta Hamamoto
What Is the MATCH Act? Bill Status, the Allied Deadline, and Chip Tool Export Impact (October 2026)
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What Is the MATCH Act? Bill Status, the Allied Deadline, and Chip Tool Export Impact (October 2026)

The MATCH Act is still a bill. What the House committee substitute changed, including a 240-day allied deadline, where Congress stands in October 2026, and what chip tool exporters should audit now.

2026-04-28Ryuta Hamamoto
What Is an ECCN? How to Read the Code and Look Up Your Product's ECCN (2026)
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What Is an ECCN? How to Read the Code and Look Up Your Product's ECCN (2026)

What an ECCN means, how to read codes like 3A001 and 5A992.c, and three ways to look up your product's ECCN, checked against the EAR as of October 2026.

2026-04-24Ryuta Hamamoto
What Is Happening with Exports to China? Key Concerns and Practical Responses for Japanese Companies
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What Is Happening with Exports to China? Key Concerns and Practical Responses for Japanese Companies

No one needs a lecture on how large the Chinese market is for Japanese companies. What has changed is the operating system around that market.

2026-02-26Ryuta Hamamoto
Export Controls 2026: US, China, EU, Japan, and Asia in One Comparison Table
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Export Controls 2026: US, China, EU, Japan, and Asia in One Comparison Table

This is Hamamoto from TIMEWELL. For any company that moves goods or technology across borders, export control is no longer a customs side task.

2026-02-26Ryuta Hamamoto
"I Didn't Know" Won't Work for U.S. Exports. The Latest Export Control Regulations, Trump Tariffs, and What Is Really Happening on the Ground
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"I Didn't Know" Won't Work for U.S. Exports. The Latest Export Control Regulations, Trump Tariffs, and What Is Really Happening on the Ground

"I Didn't Know" Won't Work for U.S. Exports. The Latest Export Control Regulations, Trump Tariffs, and What Is Really Happening on the Ground.

2026-02-26Ryuta Hamamoto

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TRAFEED(16)Export Control(7)export control(6)ECCN(5)Economic Security(4)economic security(4)BIS(3)EAR99(2)US Regulation(2)US Export Controls(2)supply chain(2)Affiliate Rule(2)compliance(2)Extraterritorial Application(1)De Minimis(1)
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