- with readers working within the Aerospace & Defence industries
The Commerce Department's Bureau of Industry and Security (BIS) issued a final rule, effective February 3, 2026, formally removing Cambodia from Country Group D:5 in Supplement No. 1 to Part 740 of the Export Administration Regulations (EAR). This amendment formally aligns BIS' regulations with the Department of State's International Traffic in Arms Regulations (ITAR), although Cambodia was effectively removed as a U.S. arms embargoed destination following the U.S. Department of November 7, 2025, final rule revising Section 126.1 of the ITAR. Together, these regulatory updates align with and implement the policy direction set forth in the White House's October 26, 2025, announcement that the United States and Cambodia had reached a reciprocal trade agreement.
The BIS and State Department rules aim to eliminate confusion for exporters, reexporters, and transferors by coordinating EAR country listings with ITAR restrictions.
Despite its removal from the Country Group D:5 list, Cambodia remains in Country Group D:1 in Supplement No. 1 to Part 740 of the EAR, and is still subject to EAR restrictions regarding military and military-intelligence end users and end uses under Sections 744.21 and 744.22.
In light of these recent regulatory developments, companies engaged in international trade should review their compliance programs to ensure that they reflect the updated designation of Cambodia under both the EAR and ITAR. While the removal of Cambodia as a U.S. arms embargoed destination reduces certain export control burdens, significant controls remain in place. Companies should continue to exercise caution and due diligence regarding end-use and end-user restrictions.
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