The Commerce Department’s Bureau of Industry and Security (BIS) has offered a pointed reminder that the Export Administration Regulations’ “de minimis” relief is a narrow accounting rule—not a design lever. In a February 26 settlement order involving Teledyne FLIR and its affiliates, BIS described how legacy FLIR practices undervalued U.S.-origin content embedded in foreign-made thermal camera systems, leading to unlicensed reexports to China.
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