The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has promulgated a Final Rule prohibiting the import and sale of connected vehicles and related components linked to the People’s Republic of China (PRC) and Russia, citing critical national security concerns. These rules represent a pivotal shift in U.S. automotive supply chain regulations, emphasizing the need for vigilance and proactive compliance by stakeholders across the industry.

Expanded Compliance Obligations

Although the final rule does not mandate formal certification, suppliers are now required to scrutinize the origins of Vehicle Connectivity Systems (VCS) hardware and Automated Driving Systems (ADS) software to ensure compliance. Suppliers must exclude components with links to the PRC or Russia, with significant implications for sourcing practices and operational processes.

To address these challenges, many suppliers are exploring partnerships with third-party certification firms to assist in supply chain mapping and regulatory compliance. These firms provide specialized support to ensure alignment with U.S. regulations:

Limited OEM Guidance

Original Equipment Manufacturers (OEMs) have provided limited direction on how they will interpret and implement the final rule. However, several have engaged in the rulemaking process through public comments and requests for compliance extensions. OEMs may eventually require declarations or certifications from their supply base, even in the absence of a formal BIS mandate. This highlights the importance of proactive supplier engagement and preparation to meet potential OEM requirements.

Implications for Automotive Suppliers

The final rule is poised to profoundly impact automotive suppliers, particularly those sourcing components from the PRC or Russia. As we previously advised, key considerations include:

Recommendations for Compliance

To mitigate risks and align with the new regulations, automotive stakeholders should take the following steps:

While the regulatory landscape remains dynamic, proactive planning, thorough due diligence, and strategic collaboration will be critical for suppliers and manufacturers to adapt to the BIS’s final rule. By aligning their practices now, companies can minimize disruptions and position themselves for long-term compliance and competitiveness in a rapidly evolving market.

Elizabeth Morales-Saucedo contributed to this article

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