The U.S. Office of Information and Communications Technology and Services (OICTS) created an Approved Supplier List governing connected vehicle supply chains and narrowed the scope of General Authorization 1, according to a regulatory alert published by law firm Holland & Knight.

The two-part action — a new vetting tool paired with a tightening of an existing authorization — extends the Commerce Department's oversight of how foreign-linked technology reaches U.S. road vehicles. OICTS operates within the Bureau of Industry and Security.

What does the Approved Supplier List change?

The Approved Supplier List introduces a clearance step that did not previously exist. Transactions involving listed suppliers presumably clear regulatory review without individual licensing, while those involving unlisted suppliers face case-by-case review.

The materials reviewed do not identify which suppliers made the list. The list itself did not appear in the Holland & Knight summary. Suppliers will likely need to apply, or be nominated, to appear on it.

For Tier 1s and Tier 2s already shipping into U.S. programs, the operational question is immediate: which existing components now require list approval before shipment continues, and what evidence Commerce will require to add a new supplier.

Why did OICTS narrow General Authorization 1?

General Authorization 1 has functioned as a blanket exception, allowing certain covered transactions to proceed without individual license applications. Narrowing it removes a category of activity from that exception. Transactions that previously cleared under the authorization now need separate review, or need the supplier to appear on the Approved Supplier List.

Holland & Knight frames the combined move as a tightening of the pathways foreign-linked automotive technology can take into U.S. assembly plants and dealer lots. The firm did not specify which transaction categories remain covered by the revised General Authorization 1 in the materials reviewed.

What supply-chain components fall in scope?

Connected vehicle supply chains cover telematics control units, cellular modems, infotainment systems, antennas, GPS chips, and the software that runs on each. Many of these components originate from suppliers with parent companies headquartered in jurisdictions the Commerce Department has flagged for national security review.

The narrowest reading of the new framework would force Tier 1s to pause shipments while waiting for list approval. The broadest reading would grandfather existing supply relationships. Commerce typically builds in transition language, but the duration of any such window remains the open question for procurement teams.

What to watch next

• Publication of the Approved Supplier List itself, including any stated criteria for inclusion
• Industry comment periods, if BIS opens one
• Formal objections or clarification requests from OEMs and Tier 1s, including through the Alliance for Automotive Innovation and the Motor & Equipment Manufacturers Association
• The first denied or delayed transactions under the revised General Authorization 1
• Updated compliance guidance from BIS to help suppliers and OEMs interpret the new framework