BIS Enforcement Action Against Coastal PVA Technology Signals Continued Scrutiny of EAR99 Exports

Apr. 20, 2026
By: Ashley J. Bodden

On April 13, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order involving an enforcement action against Coastal PVA Technology, Inc. (“Coastal”), a California-based manufacturer of polyvinyl alcohol (PVA) brushes used in semiconductor manufacturing.

According to the BIS order, Coastal engaged in 18 violations of the Export Administration Regulations (EAR) between May 2021 and May 2024 by exporting PVA brushes and related products to Chinese semiconductor entities listed on the BIS entity list. The exported items were classified as EAR99, which means they are subject to the EAR but not specifically listed on the Commerce Control List. However, BIS emphasized that a license was required since the transactions involved Entity List parties, regardless of the products classification.

BIS imposed a $1.7 million civil penalty, which is fully suspended for one year and may be fully waived pending Coastal’s full compliance with the terms of the order.

The enforcement action highlighted several key compliance deficiencies, such as lack of documented policies and procedures to identify licensing requirements; misunderstanding of EAR99 obligations, even for Entity List counterparts; and failure to screen and take appropriate steps to secure BIS authorization. These failures collectively show how gaps in compliance can lead to significant enforcement exposure.

Coastal’s PVA enforcement reflects a broader trend of heightened U.S. enforcement targeting supply chains linked to advanced semiconductor manufacturing in China. Therefore, it is important for manufacturers to conduct a comprehensive review of export classification and end-use controls; implement and update written export compliance policies; train employees on Entity List restrictions; and establish protocols for high-risk transactions.

Should you have any questions pertaining to export classification or the Entity List, or need assistance writing and implementing export control policies, please do not hesitate to contact any attorney at Barnes Richardson and Colburn.