Effective July 1, China will impose new restrictions on the export of certain aviation and space components and equipment. These items are largely shipped to the U.S., so the restrictions could have an impact on companies in the U.S. aviation and aerospace manufacturing industry that rely on imports from China.

China’s Ministry of Commerce and other enforcement authorities issued May 30 a joint announcement to strengthen export controls on the following components used in the aerospace, aircraft, and shipbuilding industries.

Product description

Sample China HS codes

Aerospace components and engine manufacturing-related equipment

8203200010, 8204110010, 8204120010, 8205400010, 8205900010, 8206000010, 8480419010, 7326901910

Gas turbine engines and gas turbine manufacturing-related equipment

8454301010, 8454309010, 6903100010, 6903200010, 6903900010, 6909110010, 6909120010, 6909190010, 8480490010, 8205900020, 8428909030, 8480600010, 7326901920, 7616991020, 9031809081, 8205900030, 6804219010, 6804229010, 8207201010, 8207209010, 8207300030, 8480419020, 8466200010, 7326901930, 9031809082

Space suit windows, visors, and related equipment



Ultra-high molecular mass polyethylene fiber-related objects

5402491010, 5501900010, 5503909010, 5806409010

Starting July 1 Chinese exporters must obtain a dual-use item export license from the Ministry of Commerce before exporting the subject items. The following documents and information will be needed for the 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
  • identification of exporter and authorized person

Exporters should also be aware that (1) bulletproof products made from ultra-high molecular weight polyethylene fiber and related items require an additional military product export license and (2) software, technology, and intellectual property used for the research and development, design, or production of the items listed above are subject to export license control.

Our recommendations

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 trade professionals can assist 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 importers’ existing export control programs.

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