1. Unified control list
On November 15, 2024, China released the first unified Export Control List of Dual-Use Items of the People's Republic of China under the Regulations on the Export Control of Dual-Use Items framework. This list consolidates previously scattered controls governing nuclear, biological, chemical, and missile-related technologies. The new list includes approximately 700 dual-use items, all requiring export permits prior to shipment. Exporters, importers, and end-users must comply with applicable regulations when engaging in transactions involving these controlled items.
A major change of the new system is the replacement of customs commodity codes (HS Codes) with an export control coding system, which is partially modeled on the U.S. Export Control Classification Number (ECCN) framework. Each dual-use item is now assigned a specific export control code, along with detailed item names and technical descriptions.
Enterprises can determine whether their goods fall under export controls by referencing the item’s:
- export control code
- official nomenclature
- description
2. Mandatory regulatory approvals
Exporters of dual-use items must get approval from relevant authorities before shipment. This includes:
- submitting technical documentation
- declaring end-use and end-user information
- ensuring items are not diverted to military or prohibited uses
3. End-user risk management system
Exporters are required to:
- establish internal end-user and end-use verification processes
- conduct due diligence on customers and intermediaries
- monitor for red flags such as links to military programs or sanctioned entities
4. Enhanced penalties for non-compliance
Violations of the dual-use regulations can result in:
- severe administrative fines
- suspension or revocation of export licenses
- placement on control or sanction lists
- criminal liability (in cases involving willful misconduct or national security threats)
