United States: BIS expands export controls to the entire supply chain
A new approach to export control
The U.S. Bureau of Industry and Security (BIS) has introduced an Approved Supplier Registry for software and component suppliers involved in the production of connected vehicles. This initiative reflects a broader evolution in U.S. export control policy, where compliance increasingly extends beyond the finished product to the entire supply chain.
The objective is to help vehicle manufacturers demonstrate that critical software and connectivity systems do not originate from suppliers linked to China or Russia.
An approved supplier registry
Under this new framework, suppliers that meet the requirements established by the BIS may be included in the Approved Supplier Registry. Companies listed in the registry can receive direct authorization from the BIS, simplifying compliance procedures for manufacturers that rely on their products and technologies.
However, inclusion in the registry is not permanent. The BIS retains the authority to remove suppliers if new national security concerns or compliance risks emerge.
A model likely to expand beyond the automotive sector
Although the registry currently focuses on connected vehicles, U.S. lawmakers are already considering extending this approach to other strategic industries.
Artificial intelligence, robotics, semiconductors, drones, telecommunications, industrial equipment and LiDAR technologies have all been identified as sectors where similar supplier verification mechanisms could be introduced in the future.
This reflects the growing importance of supply chain security in the United States’ technology and national security strategy.
Export control is becoming supply chain control
This initiative illustrates how export control continues to evolve. Regulatory authorities are no longer focusing solely on the products being exported but are increasingly examining who develops critical technologies, who supplies key components and how supply chains are structured.
For companies operating internationally, this evolution reinforces the importance of supply chain transparency, supplier due diligence and continuous compliance monitoring.