Tag

EAR

Articles about "EAR"

17 articles

17 articles (showing 12)

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

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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

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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

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ECCN Number List and Cheat Sheet [2026 Edition]: Categories 0-9 x Groups A-E, Frequent Numbers, and How They Map to Japan's Export Control Items

ECCN Number List and Cheat Sheet [2026 Edition]: Categories 0-9 x Groups A-E, Frequent Numbers, and How They Map to Japan's Export Control Items.

2026-07-06Ryuta Hamamoto

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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

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What Is the BIS 50% Rule? The Affiliates Rule Returns on November 10, 2026 — Calculation Examples and How to Prepare

The BIS Affiliates Rule expands Entity List controls by ownership. How the 50% test works, the November 10, 2026 return date, and prep steps for reexporters.

2026-05-20Ryuta Hamamoto

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What the MATCH Act Would Do to Semiconductor Export Controls (April 2026 Update)

The MATCH Act would tighten allied alignment on China semiconductor controls. What U.S. exporters and Japanese toolmakers should audit now.

2026-04-28Ryuta Hamamoto

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What Is an ECCN? How to Read One, Find It on the CCL, and Use EAR99 and de minimis (2026)

What an ECCN is, how to read the five-character code, find it on the CCL, use EAR99 correctly, and apply de minimis rules for non-US exporters.

2026-04-24Ryuta Hamamoto

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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

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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

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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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Your Company Could Be Destroyed Overnight — The Terrifying 'EAR Affiliate Rule' You Can't Afford to Ignore

Let me start with a hypothetical. One day, your company is hit with a fine of up to $1 million — about 150 million yen. The person in charge is arrested.

2026-02-17Ryuta Hamamoto