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de minimis amount of US-origin controlled content certain foreign-made direct products of US-origin technology or software certain commodities produced by any plant or major component of a plant located outside the United States that is a direct product of US-origin technology or software Exports to designated entities will not be eligible for any license exceptions under the EAR, and license applications for exports to these entities will be subject to a policy of denial with few exceptions. The Final Rule contains a “savings clause” that authorizes affected shipments to the newly designated entities, provided they were shipped prior to December 18, 2020 and are

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