China Issues Export Control List of Dual-use Items

This initiative aims at establishing a complete list of currently regulated dual-use items, without any adjustments to the specific scope of control.

On November 15, 2024, the Ministry of Commerce, the Ministry of Industry and Information Technology, the General Administration of Customs, and the State Cryptography Administration jointly issued the Export Control List of Dual-use Items (hereinafter referred to as the “New List”). It will take effect on December 1, 2024.

To operate in tandem with the Regulations on Export Control of Dual-use Items, which will also take effect on December 1, there’s an urgent need to develop a unified and comprehensive list of dual-use items subject to export control. The New List consolidates control lists from multiple regulations concerning nuclear, biological, chemical, and missile items. The involved regulations include:

• Regulations on Export Control of Nuclear Dual-Use Items and Related Technologies
• Regulations on Export Control of Missiles and Related Items and Technologies
• Regulations on Export Control of Biological Dual-Use Items and Related Equipment and Technologies
• Measures for Export Control of Chemicals and Related Equipment and Technologies

They are set to be repealed and replaced by the Regulations on Export Control of Dual-use Items from December 1, 2024. Additionally, over ten official announcements of specific control on certain dual-use items will be repealed at the same time, as they have been integrated into the New List, e.g.,

• Announcement regarding temporary export control on tri-n-butyl phosphate (issued in 2003)
• Announcement on export controls for potassium perchlorate (issued in 2021)
• Announcement concerning export control on gallium and germanium-related items (issued in 2023)
• Announcement regarding adjustments to temporary export control measures for graphite items (issued in 2023)
• Announcement related to export controls on antimony and related items (issued in 2024)

The New List draws on established international practices and organizes target dual-use items into ten major industry sectors and five categories. In an interview with media presses, an official from the Ministry of Commerce stated, “This initiative aims at establishing a complete list of currently regulated dual-use items, without any adjustments to the specific scope of control.”

Companies involved in exports are advised to consider both the New List and the 2024 Catalogue of Dual-use Items and Technologies Subject to Import and Export Licensing. If the products are listed, they are subject to dual-use export licensing requirements.

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