What is the BIS 50% Rule (Affiliates Rule)?

The BIS 50% Rule is a new U.S. export control requirement that extends Entity List and MEU List restrictions to any company that is 50% or more owned (directly or indirectly) by one or more listed entities. This includes subsidiaries, holding companies, offshore structures, and multi-layer corporate ownership.

When will the BIS 50% Rule be fully enforced?

The rule becomes fully enforceable in November 2026, but early preparation is essential due to the difficulty of uncovering hidden ownership relationships.

What are the risks of BIS 50% Rule non-compliance?

Organizations face export privilege loss, regulatory penalties, and significant shipment delays. Many companies now search for BIS 50% Rule penalties and export control enforcement as enforcement tightens.

How does Assent support BIS 50% Rule compliance?

Assent’s Enhanced Entity Screening integrates AI-powered analysis, ownership tracing, and expert review to:Identify complex indirect ownership chainsUncover offshore or layered affiliatesConsolidate beneficial ownership data across jurisdictionsApply OFAC and BIS style 50% ownership logicProduce defensible evidence for audits and licensing decisions

What is Section 232 and why does it matter for steel, aluminum, and copper imports?

Section 232 of the U.S. Trade Expansion Act allows the president to impose tariffs if imports threaten national security. Since 2018, this has led to significant tariffs on steel and aluminum, and in 2025, copper was added. Importers must now provide detailed supply chain data (such as country of smelt, cast, melt, and pour) to avoid duties up to 200%.

How can importers stay compliant with Section 232 reporting requirements?

Importers should:Collect mill test certificates, certificates of analysis, or supplier attestationsEngage suppliers early to ensure smelt/melt data is availableUse trade compliance software to trace metals back to the smelterWork with compliance experts to interpret CBP updates and avoid costly penalties

What are the risks of not complying with Section 232 tariff requirements?

If importers cannot prove the country of smelt, cast, melt, or pour, U.S. CBP may assume the material originated from a restricted country (such as Russia). This can trigger a 200% duty, shipment delays, or even having goods stopped at the border. Lack of documentation creates significant financial and operational risks.

What does country of origin (COO) mean?

COO indicates where a product was produced or manufactured. All imports require clear marking of COO, ensuring transparency and accountability for goods crossing borders. It’s the basis for everything from standard customs clearance packets to tariff analysis to compliance with regulations such as the Uyghur Forced Labor Prevention Act (UFLPA). On top of that, a part’s COO determines whether the product or part is eligible for preferential treatment under certain trade agreements.

Why is accurate country of origin data important?

Accurate country of origin data helps avoid shipment delays, unexpected tariffs, and fines. For some materials like steel or aluminum, importers must also report the country of smelt, pour, or cast — not just where the product was assembled.

How can manufacturers stay compliant with country of origin rules?

To meet country of origin compliance requirements, manufacturers need traceable, up-to-date part-level data. Using automated trade compliance software helps collect certificates of origin, assign the correct HS/HTS codes, and keep up with changing trade regulations.