Key Takeaways
- • The U.S. Bureau of Industry and Security (BIS) issued General Authorization No. 3 (GA #3) on June 18, 2026, establishing an Approved Supplier Registry that permits connected vehicle manufacturers and VCS hardware importers to conduct otherwise prohibited transactions with listed suppliers without individual specific authorizations.
- • Suppliers can now apply directly to BIS for registry approval through the Compliance Application and Reporting System (CARS), eliminating the previous requirement to work through original equipment manufacturers (OEMs) or other eligible customers to obtain authorization.
- • Connected vehicle manufacturers and VCS hardware importers relying on GA #3 must maintain declarations of conformity, monitor registry changes continuously, and preserve compliance records for a minimum of 10 years; BIS retains discretionary removal authority over listed suppliers based on national security considerations.
- • Companies owned by, controlled by, or subject to the jurisdiction of China or Russia remain ineligible to rely on GA #3 and must continue seeking specific authorizations to engage in prohibited transactions involving vehicle connectivity systems and automated driving systems components.
- • The registry applies exclusively to VCS hardware and covered software with sufficient nexus to China or Russia, creating a streamlined compliance pathway while maintaining national security oversight through ongoing BIS discretionary authority.
Summary
GA #3 eliminates this indirect pathway by granting suppliers direct access to BIS review and authorization. Suppliers can now submit applications through CARS detailing their products, customers, and mitigation measures to address potential national security risks. The BIS will evaluate applications on a case-by-case basis, determining whether specific VCS hardware or covered software presents an undue or unacceptable national security risk. Applications may cover multiple covered products and must include detailed proposals sufficient for BIS assessment, including descriptions of existing or planned controls. Once approved, both the supplier and associated products are added to the published Approved Supplier Registry, creating a transparent reference point for downstream compliance.
For connected vehicle manufacturers and VCS hardware importers, GA #3 enables transaction authorization without individual specific approvals—but only when both the supplier and relevant product appear together on the registry. Companies utilizing this pathway must declare their reliance through conformity declarations and maintain compliance records for at least ten years. Critically, organizations must continuously monitor the registry, as BIS retains discretionary authority to remove suppliers due to national security considerations or failure to comply with agreed-upon conditions. Companies owned by, controlled by, or subject to Chinese or Russian jurisdiction remain statutorily ineligible for GA #3 benefits and must pursue traditional specific authorizations.
The regulatory framework applies narrowly to connected vehicles and components with sufficient nexus to China or Russia, specifically targeting VCS hardware and covered software as defined in the Connected Vehicles Rule. BIS may condition approval on letters of assurance, mitigation agreements, or other requirements tailored to individual suppliers. This streamlined approval mechanism represents a balanced approach: it reduces administrative friction for compliant suppliers while preserving enhanced national security oversight through continued BIS discretion and mandatory ongoing monitoring obligations for downstream manufacturers and importers.
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