Key Notes:

  • Proposed rule would prohibit the import and sale of connected vehicles equipped with certain hardware or software developed, manufactured, or supplied by Chinese or Russian-affiliated entities.
  • Proposed rule would also prohibit the sale of connected vehicles manufactured by Chinese or Russian OEMs.
  • Prohibitions would take effect between 2027 and 2030.
  • If implemented, manufacturers and importers would be required to submit annual declarations of conformity.
  • BIS proposes to grant general authorizations for low-volume manufacturers or vehicles for testing, research, or show/display.
  • Public comments on the proposed rule are due by October 28, 2024.

On September 23, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released a notice of proposed rulemaking (NPRM) related to the import and sale of connected vehicles. The NPRM proposes to prohibit the import or sale of connected vehicles that are manufactured by entities owned by, controlled by, or subject to the jurisdiction or direction of the People’s Republic of China (PRC) or Russia. The NPRM also proposed to prohibit the sale or import of connected vehicles that contain “vehicle connectivity systems” or certain related software that are designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of the PRC or Russia.

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Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Kerem Bilge Kerem Bilge

Kerem advises U.S. and foreign clients on a broad range of international trade and customs matters. He represents clients in antidumping and countervailing duty proceedings before U.S. government agencies and courts. Kerem also assists clients with import compliance, including identifying risks and developing…

Kerem advises U.S. and foreign clients on a broad range of international trade and customs matters. He represents clients in antidumping and countervailing duty proceedings before U.S. government agencies and courts. Kerem also assists clients with import compliance, including identifying risks and developing strategies to remain compliant with U.S. Customs and Border Protection requirements.