USCBC Comments on Modifications of License Exception Additional Permissive Reexports (APR)

The US-China Business Council (USCBC) is pleased to provide comments to the Department of Commerce’s Bureau of Industry and Security (BIS) on the proposed rule modifying License Exception Additional Permissive Reexports (APR). USCBC represents over 220 American companies that operate in a diverse range of industries and employ millions of Americans.

USCBC also values this opportunity to provide additional thoughts regarding the two final rules expanding license requirements for Military End Use and Military End Users in China, and the elimination of License Exception Civil End Users (CIV) to countries of national security concern. We were pleased to hear that BIS is seriously considering developing additional guidance for how these rules would be implemented before they take effect in June 2020, and are grateful for BIS’s consideration of industry comments.

Our members are steadfast partners in assuring US national security, and appreciate the concerns that these new and proposed rules seek to address. USCBC has consistently advocated that export restrictions be narrowly tailored to specific national security interests, with the support of multilateral regimes, to minimize unintended consequences to American commercial interests. We are concerned the broad scope and unilateral nature of these new and proposed rules would undermine US global competitiveness, particularly in the high-technology, innovation-driven sectors that also underpin America’s national and economic security.

Read the full comment letter