Overview
If you are a Vehicle Connectivity System (VCS) hardware importer or a connected vehicle manufacturer, you may rely on General Authorizations issued by the Bureau of Industry and Security’s Office of Information and Communication Technology and Services (OICTS) to engage in an otherwise prohibited transaction pursuant to 15 C.F.R. § 791.306 if you meet the stated requirements or conditions identified in the below General Authorization Letter and are not subject to one, or more, of the following restrictions:
- BIS has notified, either directly or through an Advisory Opinion, that you are not eligible for a General Authorization; or
- You are owned by, controlled by, or subject to the jurisdiction or direction of the PRC or Russia.
Frequently Asked Questions (FAQs)
OICTS will publish General Authorizations on this website and in the Federal Register. OICTS also maintains a repository of previously issued General Authorization Letters for reference.
We recommend you subscribe to the OICTS newsletter to stay up to date with notifications and updates related to the current General Authorizations issued.
You should review the criteria identified in each General Authorization issued by OICTS. If you are unable to determine whether a particular transaction is authorized under a General Authorization, you may request an Advisory Opinion from OICTS. Visit the OICTS Advisory Opinions page for more information on submitting a request.
No. You do not need to submit a Declaration of Conformity for certain ICTS transactions authorized by a General Authorization.
However, OICTS may, at its discretion, seek verification from VCS hardware importers and connected vehicle manufacturers as to whether they are relying on a General Authorization, and if so, may request records to verify compliance.
You must keep all primary business records related to the execution of each transaction undertaken pursuant to a General Authorization. Primary business records include contracts, import records, commercial invoices, bills of sale, corporate policy documentation, and reports produced by third parties created for the purposes of compliance.
In addition, you may need to file reports and statements to OICTS according to any instructions specified in each General Authorization. Failure to fulfill instructions provided in a General Authorization may nullify the authorization and result in a violation that may be subject to BIS enforcement action.
You are required to retain records demonstrating compliance for 10 years. These records must be made available to BIS upon request.
Unless otherwise prescribed by OICTS, within 30 days of discovering a change in circumstance you must assess if you still qualify for the General Authorization.
If you determine that articles subject to a General Authorization have been used outside the conditions of the General Authorization, you must, within 30 days of such a determination, cease any prohibited conduct.
Furthermore, you must conduct an internal inquiry, and submit to OICTS a report identifying the following:
- Any prohibited transactions;
- The number of connected vehicles or VCS hardware units implicated; and
- Proposed remedial measures.
This report should be sent to OICTS at: [email protected]. Upon receipt of the report, OICTS will notify the VCS hardware importer or connected vehicle manufacturer of next steps, if applicable.
You must notify OICTS within 30 days of such a determination.
For information on how to notify OICTS, see My circumstances have changed regarding a previous transaction availed of by a General Authorization. What do I do?
You must cease any prohibited conduct, conduct an internal inquiry and submit a report to OICTS within 30 days of such a determination.
For information on how to notify OICTS, see My circumstances have changed regarding a previous transaction availed of by a General Authorization. What do I do?
Yes. Any change in the requirements of a General Authorization will apply to all connected vehicle manufacturers and VCS hardware importers going forward, including those already using a previous version of the General Authorization. Only transactions that meet the stated requirements or conditions identified in a specific General Authorization in the current OICTS-issued General Authorization Letter may be authorized by a General Authorization.
Updated or changed requirements for General Authorizations should be treated as a change in circumstance. Upon notification that a General Authorization has changed you must, within 30 days, assess if your transaction still qualifies under a current General Authorization. If you determine that the current General Authorization no longer applies, you should review carefully whether any prohibited transactions (i.e. sales or imports not authorized under the General Authorization in effect at the time) have occurred.
If you determine that articles subject to a General Authorization have been used outside the conditions of the General Authorization, you must, within 30 days of such a determination, cease any prohibited conduct, conduct an internal inquiry, and submit to OICTS a report identifying the following:
- Any prohibited transactions;
- The number of connected vehicles or VCS hardware units implicated; and
- Proposed remedial measures.
This report must be submitted to OICTS at: [email protected]. Upon receipt of the report, OICTS will notify the VCS hardware importer or connected vehicle manufacturer of next steps if applicable.
No. OICTS will not grant Specific Authorizations for transactions in which a General Authorization is applicable. Visit the OICTS Specific Authorizations page for more information on Specific Authorizations.