The Commerce Department has an appeals process for companies to try to get off the list, but it is unclear whether that would be available to ZTE because the case had been previously subject to a settlement, according to people familiar with the matter.
Even so, ZTE would have little recourse in the near term because appeals would have to be approved by the BIS, the same agency that issued the ban.
Companies must submit appeals to a committee that would issue a ruling within 30 days, according to the agency’s website.
ZTE’s best chance would be if U.S. companies choose to lobby the Trump administration to lift the ban to save their business with ZTE, said Adams Lee, an international trade attorney at Harris Sliwoski.