Global Trade & Foreign Policy Insights

On September 13, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an advance notice of proposed rulemaking (“ANPRM”) to impose export controls on automated peptide synthesizers and associated software and technology under Section 1758 of the Export Control Reform Act. BIS noted in the ANPRM that Export Control Classification Number (“ECCN”) 1C351 currently contains mostly advanced peptides and proteins that could be used as toxins for biological weapons purposes, but there is no appropriate control on the automated synthesizers or associated software and technology capable of producing those toxins.