U.S. companies that export from China will be impacted by a new China dual-use export control list that will take effect Dec. 1.
For more information on how this list may affect your business, or more details on the specific items controlled by this list, please contact Xiaofeng Xu via email.
ST&R has previously reported that that China will implement its new dual-use export control regulations beginning Dec. 1. Pursuant to those regulations, China’s Ministry of Commerce and other enforcement agencies published Nov. 15 Bulletin [2024] No. 51, which includes a consolidated dual-use export control list and a new coding system similar to the U.S. export control classification number system.
The consolidated list includes dual-use items and technology as well as existing temporary control measures released in the past ten years. One of the most significant changes is how controlled items will be identified. In the past, dual-use items were identified in China by product description and HS codes, which created complexity in determining whether a product or technology is controlled. Moving forward, China will introduce five-character alphanumeric classification like the U.S. ECCN (see appendix below for details of this system).
Xiaofeng Xu, senior manager for Sandler, Travis & Rosenberg Limited in Hong Kong, said the new regulations and new identification system are the most significant and substantial update to China’s export control system since 2003. “We anticipate that the enforcement of export controls in China will be enhanced after the new regulations become effective,” Xu said. “U.S. companies are therefore encouraged to take compliance measures to ensure a smooth transition after the regulations become effective and avoid potential violations.” Such measures should include:
- classifying goods exported from China with the new ECCNs;
- reviewing whether goods exported from China are on the consolidated list, especially components that could be used to produce dual-use items;
- developing China export control compliance processes for Chinese subsidiaries;
- collaborating with vendors from China to apply for export licenses early (because the application review period is 45 days); and
- conducting risk assessments on exports from China and leveraging voluntary disclosures to mitigate risks.
Appendix: Introduction of China ECCN
The first character indicates the applicable industry.
1 – special materials, equipment, chemicals, microorganisms, and toxins
2 – materials processing
3 – electronics
4 – computers
5 – telecommunications and information security
6 – sensors and lasers
7 – navigation and avionics
8 – marine
9 – aerospace and propulsion
0 – other
The second character indicates the product group.
A – systems, equipment, and parts
B – test, inspection, and production equipment
C – materials
D – software
E – technology
The third character indicates the reason for control.
0 – conventional weapons related items
1 – weapons of mass destruction-related items
2 – nuclear non-proliferation-related items
3 – chemical and biological weapons-related items
4 – controlled chemicals
5 – temporary control
9 – other national security-related items
The fourth and fifth characters are the serial number.
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