BIS extends ECCN 3A090.a approved IC designer application deadline from April 13, 2026 to December 31, 2026

What changed

• BIS has amended Note 1 to ECCN 3A090.a in paragraphs a.(2) and (3) by removing the date 'April 13, 2026' wherever it occurs and replacing it with 'December 31, 2026' [FR Doc. 2026-06851, Supplement No. 1 to Part 774, ECCN 3A090 amendment].
• The triggering date for authorized IC designer status and the submission deadline for applications to become an approved IC designer are both extended by approximately eight months [FR Doc. 2026-06851, SUMMARY].
• Applicants who submit by December 31, 2026 may be considered authorized IC designers for 180 days after that date [FR Doc. 2026-06851, DATES].
• BIS estimates the extension will result in approximately 20 additional approved IC designers and an increase of 385 burden hours under OMB Control Number 0694-0137 [FR Doc. 2026-06851, Rulemaking Requirements §2].
• BIS also estimates approximately 75 additional advisory opinions and 38 additional burden hours under OMB Control Number 0694-0088 [FR Doc. 2026-06851, Rulemaking Requirements §2].

Who is affected

• Front-end fabricators and OSAT companies seeking to export, reexport, or transfer (in-country) certain applicable advanced logic integrated circuits under ECCN 3A090.a are affected [FR Doc. 2026-06851, SUPPLEMENTARY INFORMATION].
• Entities that have submitted or intend to submit requests to BIS to be listed as approved IC designers, subject to End-user Review Committee (ERC) approval, are affected [FR Doc. 2026-06851, SUPPLEMENTARY INFORMATION].
• Entities seeking to qualify as authorized IC designers under the criteria in Note 1 to 3A090.a are affected [FR Doc. 2026-06851, SUPPLEMENTARY INFORMATION].

Instruments

15 CFR Part 774, Supplement No. 1 (Commerce Control List), ECCN 3A090.a, Note 1, paragraphs a.(2) and (3)

Relevance for EU exporters

indirect only

Text change

Materiality (system assessment, source-cited)

Substantive but narrow: extends a compliance window — the Note 1 to ECCN 3A090.a application deadline moves from April 13, 2026 to December 31, 2026; the scope of controlled items is unchanged [FR Doc. 2026-06851, Supplement No. 1 to Part 774, ECCN 3A090 amendment].

Action items

• EU-based IC designers or entities involved in the supply chain for ECCN 3A090.a items who seek approved IC designer status should submit applications to BIS by December 31, 2026.
• Review Note 1 to ECCN 3A090.a paragraphs a.(2) and (3) to confirm updated date references in compliance procedures.
• Assess whether front-end fabricator or OSAT operations involving ECCN 3A090.a items require reliance on the approved or authorized IC designer pathway and update timelines accordingly.