NEW BIS LICENSE TYPE C78 – (SPP) Syria Peace and Prosperity
September 2, 2025
On Tuesday, September 2, 2025 the Department of Commerce, Bureau of Industry and Security (BIS) published a final rule (https://www.federalregister.gov/documents/2025/09/02/2025-16724/relaxing-export-controls-for-syria) with an effective date of September 2, 2025 for most provisions. In this final rule, the Bureau of Industry and Security (BIS) makes changes to the Syria export control measures under the Export Administration Regulations (EAR), consistent with Executive Order (E.O.) 14312. This final rule expands the eligibility of EAR license exceptions for Syria by adding a new license exception for Syria called License Exception Syria Peace and Prosperity (SPP), amending the scope of existing License Exception Consumer Communications Devices (CCD) to add Syria to the country scope, and making additional paragraphs of existing license exceptions available for exports and reexports to Syria.
In § 740.5, currently reserved, this final rule amends the section to add License Exception SPP. New License Exception SPP will authorize exports and reexports to Syria of all items designated EAR99 subject to the terms and conditions therein and the general restrictions set forth under § 740.2 of the EAR. In § 740.5(a) (Scope) of License Exception SPP, this final rule specifies that this license exception will overcome license requirements for the export or reexport of all items designated “EAR99.” Items designated “EAR99” are items subject to the EAR but not specifically described on the Commerce Control List (CCL) in an ECCN.
In § 740.5(b) (Restrictions), this final rule adds this paragraph to specify that License Exception SPP does not authorize exports or reexports prohibited under a part 744 end-use or end-user control, including under § 744.8 for transactions involving persons designated by Office of Foreign Assets Control (OFAC) to the Specially Designated Nationals (SDN) List with certain identifiers.
This final rule as a conforming change adds a reference to License Exception SPP in § 746.9(b)(1) to specify that it is an available license exception for Syria, provided that the export or reexport is not otherwise restricted under § 740.2 and meets all the terms and conditions of License Exception SPP.
New License Code C78 Syria Peace and Prosperity (SPP)
An update has been made to AES to create new License Codes C78 “Syria Peace and Prosperity” (SPP) which authorizes certain export, reexport, and transfer (in-country) of items specified in ECCN EAR99. SPP will authorize exports and reexports to Syria of all items designated EAR99 subject to the terms and conditions therein and the general restrictions set forth under § 740.2 of the EAR. In § 740.5(a) (Scope) of License Exception SPP, this final rule specifies that this license exception will overcome license requirements for the export or reexport of all items designated “EAR99.” Items designated “EAR99” are items subject to the EAR but not specifically described on the CCL in an ECCN.
The full terms of License Exception SPP are described in § 740.5.
AES filers must adhere to the following new reporting when using C78 (SPP) to prevent the return of fatal errors from AES:
- Report License Code: C78 Syria Peace and Prosperity
- Allowable ECCNs: EAR99
- Allowable countries: Syria
- Allowable Export Information Codes: All except UG, FS, FI
- Allowable Modes of Transportation: All except ‘70’ (Fixed Transport)
A list of AES License Codes and reporting instructions can be found at https://www.cbp.gov/document/guidance/aestir-appendix-f-license-and-license-exemption-type-codes
For questions regarding these upcoming AES changes, please contact the Bureau of Industry and Security at one of the phone numbers below.
Outreach and Educational Services Division (located in Washington, DC) (202) 482-4811
Office of Technology Evaluation (located in Washington, DC): (202) 482-4933
Western Regional Office (located in Irvine, CA) (949) 660–0144
Northern California branch (located in San Jose, CA) (408) 998-8806
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