Export controls: what businesses need to know in 2026

Sanctions target countries, governments, companies and people, and can bar almost any dealing with them. Export controls target items: they decide which goods, software and technology need a licence for which destinations, end users and end uses. The two overlap, and a single deal can trigger both.

Controls cover more than physical shipments. Sending technical drawings by email, giving a foreign engineer access to controlled source code or uploading designs to a shared server can all count as exports.

US export rules follow US items around the world. Goods made outside the US can still be caught if they contain more than a set share of controlled US content, generally 25%, falling to 10% for exports to certain embargoed or high risk destinations. Some sensitive items have no minimum at all, and special rules cover foreign products made with certain US technology or equipment.

The Entity List names foreign companies that need a licence for almost any US item, and licences for them are often denied. That is why companies far from the US screen customers and suppliers against US lists.

On Sept 30, 2025, the US extended Entity List and military end user restrictions to companies owned 50% or more by listed parties. The rule was suspended from Nov 10, 2025 to Nov 9, 2026 under the US and China trade arrangement, and is set to be reimposed on Nov 10, 2026 unless the suspension is extended.

Both governments have said the arrangement is extended to Jan 10, 2027, and a further suspension is expected. As of Nov 4, 2026, no formal extension notice had been published, so the Nov 10 date still stands on paper. Companies should map the ownership of customers and distributors now, so they are ready whichever way the notice falls.

China's sweeping rare earth export measures announced on Oct 9, 2025 were suspended for one year under the same arrangement. China has said that suspension also runs to Jan 10, 2027, though as of Nov 1, 2026 the published legal notice still carried the November date. Licensing requirements China introduced earlier on several critical minerals remain in force.

For manufacturers, that means supply of magnets, battery materials and some specialty metals still depends on Chinese licence approvals, and a breakdown in talks could bring tighter rules back quickly.

Canada controls exports under the Export and Import Permits Act and its Export Control List, administered by Global Affairs Canada. Most listed items need a permit for every destination except the US, while some, marked for all destinations, need a permit even for the US. Goods passing through the US on the way to a third country still need a Canadian permit.

US origin goods leaving Canada also need a permit, and a general permit covers most destinations. Goods exported to the US become subject to US export rules from that point.

Classify each product, part, software and technology against the relevant control lists. Screen every party in the deal, including owners, against sanctions and restricted party lists. Ask about end use and end user, and watch for red flags such as unusual routing, reluctance to share end use details or payment from unrelated parties.

Keep records, train sales and engineering staff, and set triggers for review when rules change, as they will on or around Nov 10.