On 10 November 2026, Two Suspensions Expire on the Same Day — What to Finish in the Fourteen Weeks Left

Hello, this is Ryuta Hamamoto from TIMEWELL.

The confirmed facts first.

	Measure	Expiry (as written)
United States	Stay of the BIS Affiliates Rule (50 percent rule)	Stayed until 9 November 2026 (rule expected to return the next day)
China	Suspension under MOFCOM / GACC Announcement No. 70 of 2025	"From the date of issue until 10 November 2026"

The same day.

Today is 2 August 2026. Fourteen weeks.

This piece works from both primary texts and sets out what to finish in those fourteen weeks. To be clear from the outset: whether either actually returns on that date is not settled. The argument here is that you should prepare anyway.

The U.S. side: what is on hold

The BIS Affiliates Rule, generally called the 50 percent rule, works like this:

A company that is 50 percent or more owned — directly or indirectly, individually or in the aggregate — by parties on the U.S. Entity List and similar lists becomes subject to the same restrictions, even though its own name never appears on any list.

That was published as an interim final rule on 30 September 2025 (90 FR 47201).

A suspension rule followed on 12 November 2025 (90 FR 50857–50858, Vol. 90, No. 216):

Effective 10 November 2025, the amendments to 15 CFR parts 732, 734, 736, 744 and 748 made by 90 FR 47201 are stayed until 9 November 2026.

And the SUMMARY of that suspension reads:

"The suspension is set to end November 9, 2026, absent a future extension."

Absent a future extension. That phrase has to be read precisely. The return is conditional, not certain.

The China side: what is on hold

MOFCOM and the General Administration of Customs Announcement No. 70 of 2025, issued 7 November 2025.

It suspends the implementation of six announcements:

• MOFCOM / GACC Announcement No. 55 of 2025
• No. 56
• No. 57
• No. 58
• MOFCOM Announcement No. 61 of 2025
• No. 62

The subject matter covers superhard materials, certain rare earth equipment and feedstock, certain medium and heavy rare earths, lithium batteries and synthetic graphite anode materials, rare earth items outside China, and rare earth related technology.

The suspension period, as written:

"From the date of issue until 10 November 2026"

That is, from 7 November 2025 through 10 November 2026.

Why the same date

Not coincidence.

China's suspension was issued to implement the common understanding reached at the US-China Kuala Lumpur economic and trade talks. The U.S. stay followed the same late-October 2025 agreement.

The two are halves of a single arrangement, and the aligned expiry follows from that.

Which means one thing: 10 November is not a date you can watch from one side only.

What can land at once

For exporters, this date cuts both ways.

From the U.S. side. A counterparty can become restricted without ever being listed. That is the difficulty with the 50 percent rule: screening counterparty names against the lists will not surface it, because the affected company is by definition not on them. Whether aggregate ownership reaches 50 percent only shows up if you trace the shareholders.

From the China side. Rare earths, lithium battery materials, synthetic graphite anode materials, superhard materials — sourcing for these can return to licensing. For anyone in batteries, magnets, tooling or semiconductors, that reaches into the supply plan itself.

And both arrive the same week.

Whichever one absorbs your attention first, the other is landing alongside it. Processing both from a standing start in November is, candidly, not realistic.

How to treat "it might not come back"

Stated plainly: the U.S. text is conditional. An extension is genuinely possible. The Chinese measure can move with the talks.

So is the preparation wasted? No — for three reasons.

One: the work is not specific to this rule.

Mapping counterparty ownership is already required by OFAC's 50 percent rule, by MEU screening, and by ordinary counterparty due diligence. None of that disappears if the Affiliates Rule is extended.

Two: the work takes time.

This is the substantive reason. Tracing shareholders two or three layers up scales with the number of counterparties. A hundred entities is weeks; a thousand is months. It does not finish in the final fortnight.

"Wait and see whether it gets extended, then start" is not a viable strategy. By the time you can see the answer, you are out of runway.

Three: your customers will ask first.

Large customers start requesting screening records from their supply base. The suppliers who can produce them immediately are the ones who stay on the list. The ones who cannot come off — not because they did anything wrong, but because they cannot demonstrate that they did anything right.

Using the fourteen weeks

The tasks differ in nature, so the order matters.

Weeks 1–2: Scope it

What: identify which counterparties and which items could be in range.

Why first: without this you cannot size anything downstream. And this step needs no tooling — your existing counterparty and item lists are enough.

• U.S. side: which counterparties are involved with items that could be subject to the EAR
• China side: where your sourcing of rare earths, lithium battery materials, synthetic graphite anode materials and superhard materials actually sits

Weeks 3–8: Work the ownership

What: trace shareholders, starting with the highest-priority counterparties.

This is where the time goes. It is also where most programmes hit the wall of "we cannot get the data."

The important part is to record what you could not find as what you could not find. Not a blank — "traced two layers, the third is not published in that jurisdiction, checked on this date." It is unglamorous, and it is what saves you later.

An auditor or a customer asks two things: what did you conclude, and what did you do to get there. Without a record, the second has no answer.

Weeks 9–12: Fix the procedure, widen the access

What: turn the check into something that happens every time, and expand who can run it.

The second half gets skipped most often. Export control failures do not start in legal or compliance. They start when sales commits to a customer, when engineering fixes a specification, when procurement places an order. If there is no way to check at those moments, an org chart does not help.

If your internal tooling is priced per seat, then the number of people who can check is being set by budget rather than by risk. That is worth examining once.

Weeks 13–14: Close it out

What: re-screen ahead of the deadline and prepare the customer conversation.

• Re-screen the full counterparty book against current lists — before the date, not after
• Confirm what your contracts allow if a counterparty becomes restricted
• Draft the explanation for customers asking why additional diligence is being requested

And after 10 November, check the Federal Register for whether it was extended. Move on the notice, not on the date. That one habit is worth keeping.

What happens if you do nothing

The other side of the ledger. Starting in November looks like this:

• The ownership work does not finish. With no prioritisation done, time goes into deciding where to begin
• You cannot answer customer requests. "We're looking into it" gets repeated
• The Chinese sourcing impact and the U.S. counterparty impact arrive together and both get handled halfway
• And so you end up stopping transactions you cannot resolve — the most expensive option available

Stopped business does not always come back. That asymmetry is the whole argument between preparation cost and non-preparation cost.

What you can use in these fourteen weeks

Working through it internally, these help:

The BIS Affiliates Rule Readiness Checklist (PDF, free) — what the rule does mechanically, where ownership data typically breaks, and a six-phase preparation list you fill in as you go. Built to work whether the rule returns on schedule or the stay is extended.

The BIS 50% Rule quick check (free, no registration) — enter a counterparty name and it traces the ownership chain to compute aggregate holdings. Running one company tells you quickly where your own data runs out. (Currently available in Japanese only.)

When the number of counterparties passes what people can carry by hand, that is TRAFEED's range: screening counterparties against the major control and sanctions lists, investigating capital structure and affiliated networks, and attaching the supporting evidence to each determination. Pricing is based on how much you run rather than how many people log in, so you do not have to ration who is allowed to check.

Final determinations rest with your export-control officer and the authorities' current published guidance. That line does not move.

Key takeaways

• On 10 November 2026, two suspensions expire on the same day. The U.S. stay of the BIS Affiliates Rule runs to 9 November (90 FR 50857); China's Announcement No. 70 of 2025 suspends six announcements "until 10 November 2026"
• Not coincidence — both halves of the same US-China arrangement
• But the U.S. text is conditional: "absent a future extension." The return is not certain
• Prepare anyway, for three reasons: (1) the work is not specific to this rule (2) ownership tracing takes time and does not finish at the last minute (3) your customers will ask first
• Sequence for fourteen weeks: scope (1–2) → work the ownership (3–8) → fix the procedure and widen access (9–12) → close out (13–14)
• Record what you could not find. Auditors ask for the process, not only the conclusion
• Starting in October is too late. Stopping transactions you cannot resolve is the most expensive outcome

If you are unsure whether your current setup is enough, get in touch. We will start from how you actually run things today and map what fourteen weeks can realistically cover.

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Sources

1. One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities — Bureau of Industry and Security — published 12 November 2025 — 90 FR 50857 — https://www.govinfo.gov/content/pkg/FR-2025-11-12/html/2025-19846.htm
2. Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities — Bureau of Industry and Security — published 30 September 2025 — 90 FR 47201
3. MOFCOM / GACC Announcement No. 70 of 2025, suspending MOFCOM / GACC Announcements Nos. 55, 56, 57 and 58 and MOFCOM Announcements Nos. 61 and 62 of 2025 — Ministry of Commerce of the People's Republic of China — 7 November 2025 — https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_b1ec77dd3f0d4762952904df7cdaadec.html
4. 15 CFR Part 744 — End-User and End-Use Based Controls; Supplement No. 4 (Entity List); Supplement No. 7 (MEU List) — eCFR
5. Consolidated Screening List — International Trade Administration — https://www.trade.gov/consolidated-screening-list

※ Listing or becoming subject to a control is a regulatory classification, not a judgement about a company. Content reflects primary sources from the respective governments confirmed as of 2 August 2026. Dates and scope may be extended or amended. Treat the authorities' current published guidance as authoritative and route final determinations through your export-control officer.