***
[1] The regulation also highlights trade with Russia. See https://public-inspection.federalregister.gov/2025-00592.pdf
[2] https://www.federalregister.gov/documents/2024/09/26/2024-21903/securing-the-information-and-communications-technology-and-services-supply-chain-connected-vehicles
[3] https://www.bis.gov/press-release/commerce-finalizes-rule-secure-connected-vehicle-supply-chains-foreign-adversary
[4] The final 213 page report reviews the comments received by officials and notes whether adjustments to the draft regulation were deemed necessary. There were a total of 54 instances where the report noted that BIS "rejects," "declines," or "does not believe" that proposed adjustments were necessary.
[5] https://oilprice.com/Energy/Energy-General/Visualizing-the-Global-Footprint-of-Tesla-and-BYDs-EV-Factories.html
[6] https://oilprice.com/Energy/Energy-General/Visualizing-the-Global-Footprint-of-Tesla-and-BYDs-EV-Factories.html
[7] China’s electric-vehicle leader BYD posts record sales in 2024
[8] Supply Chain Latest: European and US trade relationship - Bloomberg
[9] The definitions in Chapter 17 run for more than 3 pages, with another two pages on scope. See Chapter 17 at https://www.international.gc.ca/trade-commerce/trade-agreements-accords-commerciaux/agr-acc/tpp-ptp/text-texte/17.aspx?lang=eng
[10] https://www.techopedia.com/largest-tesla-shareholders
[11] https://www.marketscreener.com/quote/stock/BYD-COMPANY-LIMITED-12615771/company-shareholders/
[12] The proposed draft included the following text, which was not revised in the final regulation (beyond the addition of clarifying examples): BIS proposed to define "person owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary" to mean:
"(1) Any person, wherever located, who acts as an agent, representative, or employee, or any person who acts in any other capacity at the order, request, or under the direction or control, of a foreign adversary or of a person whose activities are directly or indirectly supervised, directed, controlled, financed, or subsidized in whole or in majority part by a foreign adversary;
(2) Any person, wherever located, who is a citizen or resident of a foreign adversary or a country controlled by a foreign adversary, and is not a United States citizen or permanent resident of the United States;
(3) Any corporation, partnership, association, or other organization with a principal place of business in, headquartered in, incorporated in, or otherwise organized under the laws of a foreign adversary or a country controlled by a foreign adversary; or
(4) Any corporation, partnership, association, or other organization, wherever organized or doing business, that is owned or controlled by a foreign adversary, to include circumstances in which any person identified in paragraphs (a) through (c) possesses the power, direct or indirect, whether or not exercised, through the ownership of a majority or a dominant minority of the total outstanding voting interest in an entity, board representation, proxy voting, a special share, contractual arrangements, formal or informal arrangements to act in concert, or other means, to determine, direct, or decide important matters affecting an entity." See page 81: https://public-inspection.federalregister.gov/2025-00592.pdf
[13] See page 92, https://public-inspection.federalregister.gov/2025-00592.pdf
[14] https://iea.blob.core.windows.net/assets/4eb8c252-76b1-4710-8f5e-867e751c8dda/GlobalSupplyChainsofEVBatteries.pdf
[15] https://cdn.cta.tech/cta/media/media/pdfs/cta-comments-bis-nprm-docket-no-240919-0245.pdf