09/02/2026
The United States’ recent enforcement action involving Robert Bosch GmbH demonstrates why that assumption can be wrong.
On June 17, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security announced that Bosch had agreed to pay a civil penalty of approximately $36.2 million to resolve alleged violations involving foreign-produced sensors and automotive software supplied to Huawei and its affiliates.
According to BIS, two non-U.S. Bosch subsidiaries supplied approximately $72.4 million in micro-electromechanical systems sensor products and foreign-produced automotive software to Huawei-related entities between September 2020 and September 2024 without obtaining the required U.S. authorization.
The products were manufactured outside the United States.
The sellers were foreign subsidiaries.
The customer was outside the United States.
Nevertheless, the U.S. government determined that the items were subject to the Export Administration Regulations because of the Foreign Direct Product Rule.[1]
The Justice Department separately investigated the conduct but declined to prosecute Bosch after considering the company’s voluntary disclosure, cooperation, remediation, and the absence of aggravating circumstances. Bosch agreed to disgorge approximately $11.4 million in profits, with credit given for a portion of the Commerce Department payment.[2]
The case is significant for much more than Bosch or Huawei.
It demonstrates that U.S. export controls may follow American technology, software, production equipment, and technical know-how into foreign manufacturing operations.
For U.S. and international business owners, the central lesson is:
The location where a product was made is only the beginning of the export-control analysis.
A company may also need to determine:
🔘 Which technology was used to design the product;
🔘 Which software was used to develop or manufacture it;
🔘 Which equipment produced it;
🔘 Whether that equipment was derived from U.S. technology;
This is just a snippet. Want to read the full article? Click here: https://www.teilfirms.com/blog/made-abroad-does-not-mean-outside-us-export-law-lessons-from-the-boschhuawei-settlement
