Authored by: Dai Menghao , Zheng Ziyi , Zhang Jiarou and Fu Yanru
On September 23, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) following its review of the information and communications technology and services (ICTS) supply chain for connected vehicles, targeting the People’s Republic of China, including the Hong Kong Special Administrative Region (PRC or China), and the Russian Federation (Russia). This comes six months after BIS released an advance notice of proposed rulemaking (ANPRM) on March 1, 2024, concluding its ICTS review on connected vehicles. As the first major rulemaking after BIS was formally delegated the ICTS review authority, the stringent requirements outlined in the NPRM suggest that the review will become a powerful tool alongside export controls. This development is expected to have far-reaching effects on global trade. In this article, we analyze the NPRM’s implications in light of its content and the recent U.S. regulatory trends concerning China’s automotive industry.