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Ref.: TRA CR 1015/35
TRA CR 1015/33/1

 12 May 2020


Strategic Trade Controls Circular No. 3/2020


Re-exports of U.S.-origin Electronics, Computers and
Telecommunications from Hong Kong


              This circular informs traders of the elimination of U.S. Licence Exception Civil End Users (“Licence Exception CIV”) which will affect the exports, re-exports and transfers of certain U.S.-origin electronics, computers and telecommunications products starting from 29 June 2020.


2.          On 28 April 2020, the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce published a final rule (referred as “the rule” hereafter) announcing the elimination of Licence Exception CIV.  The rule can be found at the following web link:

3.          With effect from 29 June 2020, US export authorisation, which is usually in the form of an individual validated licence issued by the BIS, will be required for exporting/ re-exporting/transferring items previously covered by Licence Exception CIV to countries/ places in Group D:1 Note.  The items affected include, for example, electronics, computers and telecommunications products under Export Control Classification Numbers (“ECCN”) 3A001.a.3, 3A001.a.7, 3A001.a.11, 4A003.g, 5A001 and their sub-categories.
4.         There is no change to Hong Kong’s import and export licensing control on strategic commodities as required under the Import and Export Ordinance (Chapter 60 of the Laws of Hong Kong) and the Import and Export (Strategic Commodities) Regulations (Chapter 60G of the Laws of Hong Kong).

5.          To facilitate Trade and Industry Department (“TID”)'s consideration of strategic commodity licence applications, applicants are often required to provide additional supporting documents which include but not limited to valid export authorisations issued by the products’ originating countries/places.  In light of the rule, traders importing/exporting the US-origin products concerned are advised to liaise and check with their U.S. exporters/manufacturers, particularly to obtain the necessary and applicable US export authorisation.

6.           In this connection, strategic commodity licences previously issued by TID featuring “U.S. Licence Exception CIV” under the "Export Authorisation of Foreign Exporting/Product's Originating Country (Place)” should no longer be used after 29 June 2020.  TID will liaise with the licensees concerned to revise the licences’ validity period and/or cancel the unused licences.


7.           If you have any enquiry concerning this circular, please contact Miss Cas Lam at telephone number 2398 5575 or by email at

Strategic Trade Controls Branch
Trade and Industry Department

Note: Countries/Places in Group D:1 and eligible for Licence Exception CIV as stipulated in the U.S. Export Administration Regulations include: Armenia, Azerbaijan, Belarus, Cambodia, the Mainland of China, Georgia, Iraq, Kazakhstan, Kyrgyzstan, Laos, Libya, Macau, Moldova, Mongolia, Russia, Tajikistan, Turkmenistan, Ukraine, Uzbekistan, Venezuela, Vietnam, and Yemen.



Last Revision Date : 11 May 2020