On June 30, 2020, the U.S. Bureau of Industry and Security issued a notice suspending “any License Exceptions for exports to Hong Kong, reexports to Hong Kong, and transfers (in-country) within Hong Kong of items subject to the Export Administration Regulations (EAR), 15 CFR Parts 730-774, that provide differential treatment than those available to the People’s Republic of China.” 

As the notice explains, items subject to the EAR that are exporting to, re‑exporting to, or transferring within Hong Kong cannot be moved under a license exception unless the items would be otherwise eligible for a license exception if exported to China.  As a kind of savings clause, shipments removed from license exception eligibility in light of the notice but that were “on dock for loading, o[r] laden aboard an exporting or transferring carrier, or en route aboard a carrier to a port of export or reexport on June 30, 2020, pursuant to actual orders for export to Hong Kong, reexport to Hong Kong, or transfer within Hong Kong, may proceed to their destination under the previous License Exception eligibility.”

These changes are effective June 30, 2020.

The notice can be found here:

https://www.bis.doc.gov/index.php/documents/pdfs/2568-suspension-of-license-exceptions-for-exports-and-reexports-to-hong-kong/file [Note: Expeditors has edited for clarity the notice’s original language of “on dock for loading, on lighter, laden aboard” to “on dock for loading, o[r] laden aboard.”]