De minimis threshold
The percentage of US-origin content above which a foreign-made item is treated as US-origin for purposes of US re-export controls under the Export Administration Regulations (EAR).
The de minimis threshold is the technical lever by which US export-control jurisdiction reaches foreign-manufactured products containing US-origin technology, components, or software. The standard threshold for most destinations is 25% — a foreign-made item with 25% or less US-origin content (by value) is generally exempt from EAR re-export controls. For embargoed destinations (Cuba, Iran, North Korea, Syria) and certain restricted destinations, the threshold drops or disappears. For certain categories of controlled technology, the threshold drops to 10% or 0%.
For Israeli industry, the de minimis threshold is the central design lever by which Israeli system architecture is built to be either "EAR-jurisdictional" (above threshold, subject to US re-export licensing) or "EAR-free" (below threshold, free of EAR re-export controls). Israeli defense and dual-use manufacturers typically build two product configurations where market access demands it — one with US-origin components above the threshold for the US and adjacent markets, one designed below the threshold for export to markets where US authorization would be slow, conditional, or unavailable.
The threshold does not apply to ITAR-controlled defense articles on the US Munitions List — those carry effectively no de minimis exception and pull any foreign-incorporated US-origin defense content into ITAR jurisdiction regardless of percentage.
Sources: US Bureau of Industry and Security; Export Administration Regulations §734.4; published trade-compliance commentary. Data current as of Q2 2026.
Read Next in The Olam: Strategic Technology Trade · EAR · ITAR · Foreign Direct Product Rule · The US Export-Control Regime and Israeli Dual-Use Technology