[Q&A] Key Points of China's Dual-Use Export Control List
2025. 1. 2
Question: What should be noted about the "Export Control List of Dual-Use Items of the People's Republic of China"?
Answer: Nearly four years after the introduction of the "Export Control Law of the People's Republic of China" in December 2020, the "Export Control List of Dual-Use Items of the People's Republic of China" (hereinafter referred to as the "List") was officially released on November 15, 2024, and came into effect on December 1.
Before the release of the "List" the definition of controlled items mainly referred to the relevant provisions of the "Catalogue of Dual-Use Items and Technology Import and Export License Management" jointly issued by the Ministry of Commerce and the General Administration of Customs. The scope of items was determined by their names and descriptions, and customs codes were used for reference during customs declaration, which led to some ambiguity in control rules in practice.
In the future, except for controlled chemicals, all other administrative regulations involving the control of dual-use items will be abolished, and control will be carried out through the "List" The "List" adopts a more systematic, transparent, and precise classification system. Each controlled item is assigned a five-digit export control code, and explanations of ambiguous concepts and definitions of relevant terms have been added, improving the certainty of identifying controlled items.
After the release of the "List" some items that were not previously controlled due to unclear definitions may now fall under control. It is recommended that enterprises promptly review the items they intend to export according to the latest "List". If they are unsure, they should consult the Ministry of Commerce and simultaneously provide the performance indicators, uses, and reasons for uncertainty regarding whether the items fall under dual-use items for accurate judgment.