Further to our recent post on the key implications of the U.S. revoking Hong Kong’s ‘special trade status’, the Bureau of Industry and Security (BIS) announced on June 30, 2020, that it is suspending license exceptions for goods that were previously subject to differential treatment than license exceptions available to Mainland China.
This applies to exports, re-exports, or transfers of goods to or within Hong Kong. The rule came into effect on the same day, but does not impact goods were already on the dock for loading, already loaded, or already en route on this date.
Goods that are deemed for export or re-export transactions (subject to meeting certain criteria) are also exempt from this requirement until August 28, 2020, after which the license exception would no longer apply.
Companies that are planning on shipping strategic commodities to Hong Kong from June 30, 2020, onwards should obtain the relevant Export License and pay attention to relevant restrictions as announced by the BIS.