BIS Contemplates Export Restrictions on "Electronic Waste" to Combat Supply Chain Concerns
Client Alert | less than 1 min read | 10.23.18
On October 23, 2018, the Department of Commerce Bureau of Industry and Security (BIS) published a notice seeking comments on imposing export control restrictions on electronic waste in response to concerns that unregulated recycling of electronic waste is a source of counterfeit goods. BIS has proposed to define electronic waste, prohibit electronic waste export, establish electronic waste exemptions, and require an export license to ship exempted electronic waste abroad. The Bureau is seeking public comment until December 24, 2018 on all aspects of the proposal including the definition, methods of tracking exported electronic waste, costs, and the likely effectiveness of the regulations.
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On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch.
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