AEA Submits Comments on Proposed Change to the De Minimis Rule

SUMMARY: The de minimis rule, as it currently exists in the Export Administration Regulations (EAR), allows entities to purchase U.S. articles and incorporate the U.S.-sourced parts into foreign-made items with the assurance that the foreign-made items then can be exported to third-party nations without worrying about the impact of U.S. export regulations, as long as the foreign product contains less than 25 percent (or 10 percent for re-export to certain controlled countries) of U.S.-sourced parts.

The U.S. Department of Commerce, Bureau of Industry and Security Regulatory Policy Division has proposed to eliminate the de minimis rule, which would have a catastrophic affect on the ability for U.S. avionics manufacturers to forward-fit certain technologies into new aircraft.

AEA COMMENTARY: The AEA strongly opposes the proposed change in the de minimis standard.

The AEA’s comments address issues with the proposed rule change and explain why the AEA believes the rule change would be detrimental to the U.S. avionics industry.

Click here to view AEA’s comments.

Contact Ric Peri, AEA vice president of government and industry affairs, by email at or by phone at 202-589-1144.