Effective Sept. 15, China will impose new restrictions on exports of the following materials, components, and equipment used in the semiconductor, defense, and battery manufacturing industries. Many of these exports currently go to the U.S., and the forthcoming restrictions could therefore present difficulties for U.S. companies in these industries that rely on importing covered items from China.
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Product description
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Sample China HS codes
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Antimony ore and raw materials, antimony metal and its products, antimony oxide, trimethyl antimony, triethyl antimony and other organic antimony compounds, antimony hydride, indium antimonide
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2617.10.1000, 2617.10.9001, 2617.10.9090, 2830.90.2000, 8110.10.1000, 8110.10.2000, 8110.20.0000, 8110.90.0000, 2825.80.0010, 2931.90.0032, 2850.00.9020, 2853.90.9031
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Six-sided press equipment and components
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8479.89.9956, 8479.90.9020, 9032.89.9094
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Microwave plasma chemical vapor deposition equipment
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8479.89.9957
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Diamond window material
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7104.91.1010
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Beginning Sept. 15, Chinese exporters must obtain a dual-use item export license from the Ministry of Commerce before exporting these items. The following documents and information will be needed for export license applications: export contract or agreement, technical explanation or examination report, proof of end-use and end-user, briefing on importer and end-user, and identification of exporter and authorized person.
Exporters should be aware that (1) in addition to the normal export license approval process such goods will be subject to national security review and (2) technology for the production of these items is also subject to export license control.
U.S. importers of affected goods should review consignments from China with identical or similar products as those listed above, assess the potential impact of this change on their operations, and prepare in advance to avoid any potential risks.
ST&R can help importers in these efforts by (1) reviewing the classification, function, and technical specifications of products to determine if they fall under China's export control regulations, (2) examining end-use and end-user documents before an export license application is submitted, (3) working with Chinese exporters to facilitate the proper license application process and ensure compliance with applicable China Customs regulations, and (4) developing or incorporating a China export control process into existing export control programs.
For more information or help taking these steps, please contact Xiaofeng Xu at (852) 2603 9350 or via email.
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