Comments Requested on New Export Licensing Rule Affecting Imagery Analysis Software

On January 6, 2020, the Commerce Department’s Bureau of Industry and Security (BIS) published an interim final rule to make certain items subject to the Export Administration Regulations (EAR) and to impose a license requirement for the export and reexport of those items to all destinations, except Canada.

Specifically, the rule classifies software specially designed to automate the analysis of geospatial imagery, as specified, under the Export Control Classification Number (ECCN) 0Y521 series, specifically under ECCN 0D521.

BIS adds this item to the 0Y521 series of ECCNs upon a determination by the Department of Commerce, with the concurrence of the Departments of Defense and State, and other agencies as appropriate, that the items warrant control for export because the items may provide a significant military or intelligence advantage to the United States or because foreign policy reasons justify control, pursuant to the ECCN 0Y521 series procedures.

View BIS rule at

The BIS notice includes a request for public comments on the rule. Comments are due March 6, 2020.

Submit/view comments at