BIS MEU List

The Military End User (MEU) List is maintained by the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and published as Supplement No. 7 to Part 744 of the Export Administration Regulations (EAR). It names foreign entities that BIS has determined are "military end users" for purposes of EAR §744.21, which restricts the export, reexport, or in-country transfer of specified items when destined for military end users or military end uses in China, Russia, Venezuela, Burma, and Belarus.

The list was introduced in December 2020, when BIS published an initial tranche of 103 entities — 58 in China and 45 in Russia — to give exporters clearer notice of who qualifies as an MEU. Importantly, the list is non-exhaustive: an entity's absence does not mean it is not a military end user, and exporters retain an independent "know your customer" due-diligence obligation under the EAR.

A "military end user" is defined broadly to include the national armed services, national guard, national police, government intelligence or reconnaissance organizations, and any person or entity whose actions or functions are intended to support military end uses. Once a party is listed, exports of items enumerated in Supplement No. 2 to Part 744 require a BIS license, generally reviewed under a policy of denial.

The MEU List should not be confused with related BIS instruments:

• The Entity List (Supplement No. 4 to Part 744) imposes party-specific license requirements often broader in item scope.
• The Unverified List flags parties BIS could not verify in end-use checks.
• The Military Intelligence End User (MIEU) List (Supplement No. 7's companion under §744.22) targets intelligence-affiliated entities.

BIS updates the MEU List through Federal Register notices, with additions, removals, and modifications driven by interagency review involving Commerce, State, Defense, and Energy.