On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule in which it announced that it was rescinding in its entirety an earlier Interim Final Rule issued during President Joseph Biden’s Administration that imposed new export license requirements for firearms and related ammunition and components. The Final Rule also removes the Congressional notification requirement for certain semi-automatic firearms license applications but does continue to ensure that appropriate controls are in place for certain firearms, related devices and ammunition. This rule is effective September 30, 2025.

This Final Rule revises the Export Administration Regulations (EAR) in response to public comments BIS received on the Interim Final Rule, “Revision of Firearms License Requirements,” published on April 30, 2024. See Thompson Hine Update of April 30, 2024. As a result, export controls on firearms are essentially restored to the state they were at end of President Donald Trump’s first administration. BIS emphasizes that it may still request additional information or support documentation from a license applicant. This will continue to allow BIS and its interagency partners enough latitude to review and properly adjudicate BIS licenses involving destinations, end-uses, or end-users of concern, as well as to deny license applications that would involve unlawful end-uses or otherwise be contrary to U.S. national security and foreign policy interests.

Overview of Revisions to ECCNs 0x5zz

This Final Rule returns the license review policy and other license support documentation requirements for ECCN 0x5zz items to those that were in effect prior to May 30, 2024, the effective date of the earlier Interim Final Rule. The earlier Interim Final Rule introduced four new ECCNs to the Commerce Control List (CCL): 0A506 for semi-automatic rifles, 0A507 for semi-automatic pistols, 0A508 for semi-automatic shotguns, and 0A509 for certain parts and components related to these firearms. These new ECCNs were intended to better enable BIS to prioritize enforcement resources and mitigate diversion risks for rifles, pistols, shotguns, ammunition, and related parts, components, accessories, attachments, software, and technologies. 

The Final Rule corrects excessive or incorrect descriptions that specify certain features or accessories. As a result of these revisions, ECCNs 0A506, 0A507, and 0A508 will use standardized and simplified item paragraph descriptions that are intended to allow exporters to correctly and more easily identify their products. The Final Rule also revises the “reason for control” of certain ECCNs to remove “crime control” (CC) as a reason for control, and also makes revisions to several License Exception categories.

The discussion in the Final Rule on the revisions to the ECCN categories is detailed and should be reviewed closely for proper applicability.

Removal of Congressional Notification Requirement

In a June 1, 2022, firearms-related final rule, BIS implemented a Congressional Notification Requirement for license applications to export certain high-value semi-automatic firearms to specific countries and valued at $4 million or more, mirroring a similar International Traffic in Arms Regulations (ITAR) provision, but with a different scope once such items were removed from control under the ITAR and transferred to the EAR. In the September 30, 2025, Final Rule, BIS has removed this requirement as unnecessary and burdensome, stating that sufficient Congressional oversight remains available through other statutory processes.

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

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…

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 Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.