On April 12, local time, the US Department of Commerce announced that more than 20 companies in China (including Hong Kong), Singapore, Turkey and other countries were included in the entity list, and 12 Chinese companies were electronic component traders, and the reason given by the United States was that these companies were accused of supporting the Russian military.
The following are 12 Chinese enterprises included in the Entity List (for reference only, please correct any mistakes):
3HC Semiconductors (HK) Co., Ltd., (xx Technology Co., Ltd.)
2、Allparts Trading Co.,Ltd.,
3、Avtex Semiconductor Limited,
4、ETC Electronics Ltd.,
5、Leadway Technology Limited, (xx Technology Co., Ltd.)
6. Maxtronic International Co., Ltd., (xx Ltd.)
7. Newsuntech Electronics Limited (xx Electronics Co., Ltd.)
8. STK Electronics (HK) Co., Ltd., (xx Electronics Co., Ltd.)
9, Wynn Electronics Co. Ltd., (xx electronic components)
10、Xinnlinx Electronics Pte Ltd.,
11、Yishang Network (Shenzhen) Co., Ltd.,
12、Yongli Electronic Components (Shenzhen) Co., Ltd. （xx电子）
Chip trade has not yet recovered, the US stick one after another, the chip industry in the entire downward cycle seems to be difficult. From one to two to the current 12, the change in US policy seems to have signs of tilting towards traders, and how to avoid risks in the future and hold the orders in hand is the primary problem for each chip person.
01
Chip traders have been targeted many times
The Entities List, which initially included only entities that used or delivered weapons of mass destruction, has expanded since Huawei and has now become a "nirvana" for the United States to curb Chinese high-tech companies.
Recently, chip traders have become a new "focus target" in the United States. Since March, the United States has successively included 13 Chinese chip traders in the entity list, and two Chinese chip traders on the unverified list, this time it is a fire trader. It can be seen that the US sanctions against Chinese companies have spread from technology entities to circulation.
Some of the chip traders included in the list are as follows:
xx company was established in 2004, mainly engaged in electronic components. After years of expansion, the company has established a good reputation and high-quality service at home and abroad. Has been committed to supplying a variety of electronic components, such as capacitors, resistors, inductors, diodes, transistors, light-emitting diodes, crystal oscillators, integrated ICs and other electronic components.
xx company, founded in 2004, the company is headquartered in Toronto, Canada, and has set up branches in Hong Kong, Beijing, Chengdu, Xi'an, Nanjing. After 19 years of development, it focuses on the high-end market of industrial electronics and forms close cooperation with front-end customers in the industry. The main products cover: RF microwave components, power modules and chips, ultra-high-speed DAC chips, MCU and DSP main control chips, MOS, IGBTs, etc.
xx company was established in 2003, is a professional sales of electronic components, power modules, aluminum electrolytic capacitors, solid capacitors, super capacitors agents.
02
What is the impact of being on the list?
How to deal with it?
The Entity List usually refers to the Export Control Regulations (EAR) established by the United States to safeguard its national security interests.
Simply put, the Entity List is a "blacklist" of the United States. Once on this list, sanctioned companies will suffer adverse effects in terms of supply chains and foreign traders:
1. Impose license requirements
The export, re-export or (domestic) transfer of EAR-controlled items to listed entities requires a licence in accordance with the specific requirements of the Entity List (whether the listed entity is a buyer, intermediate consignee, final consignee or end-user in the transaction).
2. Other entities shall not assist in engaging in illegal transactions of EAR
Unless a licence is obtained, it may also be contrary to the EAR to provide the listed entity with EAR controlled items or provide services related to the acquisition of EAR controlled items to listed entities by any means, except for entities on the Entity List.
After being included in the Entity List, if the company does not comply with the above regulations, the company may face administrative or criminal liability if it violates the procurement of controlled items in violation of the above regulations: the company will pay hefty fines, and the company executive may face the risk of extradition by the US government.
Previously, the United States has repeatedly included Chinese enterprises in multiple lists such as the Entity List and the Unverified List, which will affect the trading activities of the listed enterprises, but the jurisdiction and measures of each list are different. Here are the differences in the various lists:
Source: OFILM's Chief Compliance Officer
What should traders do?
Under many "precedents", chip traders need to pay attention to trade compliance and prudence when doing foreign trade.
Here's how to determine whether a product is regulated:
The picture shows the export licensing process
1. First of all, we must determine whether it is subject to EAR control;
2. Secondary classification of all products subject to EAR control, that is, to determine whether they have the corresponding ECCN number on the CCL (Commercial Control List);
3. For ECCN numbers, first check the classification of control reasons under the requirements of the CCL license, and the corresponding national restrictions;
4. If none of the above processes are passed, you must apply for an export license from the U.S. Bureau of Industry and Security (BIS).
Specifically, transactions involving export control regulations need to carefully check the situation that the product and its parts are subject to EAR, conduct background screening on customers and relevant parties to the transaction, and sign relevant compliance letters before the transaction, promising that there is no risk of violating the EAR. Where circumvention or illegal acts have been confirmed, the transaction shall be terminated.