New restrictions on sourcing vehicle communications tech from China or Russia

The U.S. Department of Commerce has published new proposed restrictions on importing hardware for wireless communication systems in vehicles. Imports of covered components from China or Russia and certain related suppliers would be prohibited without prior authorization, which requires proof neither China nor Russia controls relevant communication systems. All other imports would be permitted only after informing the Department of Commerce how the importer confirmed neither China nor Russia was involved.

This new restriction would apply to “Vehicle Connectivity Systems,” generally meaning the enabling of radio frequency communications over 450 megahertz, for vehicles operating primarily on public roads. The hardware covered would include the following:

• Microcontrollers
• Microcomputers or modules
• Systems on a chip
• Networking or telematics units
• Cellular modem/modules
• Wi-Fi microcontrollers or modules
• Bluetooth microcontrollers or modules
• Satellite navigation systems
• Satellite communication systems
• Other wireless communication microcontrollers or modules
• External antennas

The hardware restrictions would go into effect either in 2029 or 2030, depending on the vehicle model year involved. Limited exceptions to the rules would exist but would likely not be significant for larger companies. Additional restrictions would apply to imports and sales of vehicles themselves.

The Department of Commerce will accept comments on this proposal through Oct. 28, 2024.

For more information, please contact Corey Norton or any member of the International Business & Trade practice group.