In 2026, China’s export control system enters its strictest regulatory cycle in history. The dual-use items list continues to expand, steel export licensing is reinstated after a 16-year hiatus, and multiple rounds of rare earth controls are tightened β cross-border e-commerce sellers who don’t know whether their products are controlled may face return, confiscation, or even criminal liability.
I. Export Control Legal Framework Quick Reference
| Regulation | Issuing Authority | Key Points |
|---|---|---|
| Export Control Law | NPC | Effective 2020.12.01, foundational legislation |
| Dual-Use Items Export Control Regulations | State Council | Effective 2024.12.01, full coverage of military-civilian dual-use items |
| Dual-Use Items Export Control List | MOFCOM / GAC | Updated 2025.10 (includes 25 rare metals including rare earths) |
| 2026 Announcement No. 23 | MOFCOM | π΄ 2026.06.22: 10 U.S. entities added to control list |
| Unreliable Entity List Provisions | MOFCOM | Effective 2020.09, prohibits transactions with listed entities |
II. Prohibited/Restricted Export Classification Quick Reference
π΄ Prohibited Exports
| Category | Basis |
|---|---|
| Goods listed in the Prohibited Export Goods Catalog | MOFCOM Announcements |
| Certain rare earth ores and smelting/separation products | MOFCOM Announcement (expanded from 2025.11, partially suspended until 2026.11) |
| Precious animals, plants, and products thereof | CITES Convention |
| Specific sensitive technologies and data | Prohibited and Restricted Export Technology Catalog |
π‘ Restricted Exports (License Required)
| Category | Effective Date | Basis |
|---|---|---|
| Dual-use items (military-civilian) | 2024.12 | Dual-Use Items Export Control List |
| Steel products (300 HS codes) | 2026.01 | π΄ Reinstated after 16 years; apply with export contract + quality inspection certificate |
| Tungsten, tellurium, bismuth, molybdenum, indium (25 rare metals) | 2025.02 | 2025 Announcement No. 10 |
| Superhard materials (synthetic diamond/CBN) | 2024.08 | Included in dual-use items list |
| Drones and high-performance components | Ongoing | MOFCOM Announcement, strictly prohibited without license |
| Graphite/gallium/germanium (key semiconductor materials) | 2023 | Included in dual-use items list |
III. DDP Export Compliance Checklist
| # | Check Item | Pass Criteria |
|---|---|---|
| 1 | Is the product prohibited from export? | Check the Prohibited Export Goods Catalog |
| 2 | Does the product require an export license? | Check dual-use items list + all license catalogs |
| 3 | Is the HS code correct? | Two-way check: China export + destination country import |
| 4 | Is the brand registered with customs? | Check customs IPR filing system |
| 5 | Are all certifications complete? | Destination country required certifications (FCC/CE/FDA, etc.) |
| 6 | Is anti-dumping applicable? | Whether the destination country has anti-dumping duties on this category |
| 7 | Certificate of origin | Confirm domestic content ratio meets thresholds |
| 8 | Packaging compliance | Wood packaging fumigation, labeling language |
IV. FAQ
Q: I export ordinary clothing (non-branded). Do I need an export license?
A: No. Clothing (HS Chapters 61-62) is not on the control list; normal export customs declaration suffices. However, branded clothing must be pre-filed in the customs IPR system.
Q: What procedures are required for exporting products containing lithium batteries?
A: Lithium battery products themselves are not restricted by “export controls,” but transportation requires UN38.3 test reports + MSDS. Note: Lithium battery manufacturing equipment/technology is subject to dual-use controls, but ordinary finished products containing lithium batteries are not.
Q: When will the controls suspended in 2026 be reinstated?
A: On November 7, 2025, it was announced that export controls on superhard materials, some rare earths, lithium battery equipment, etc. are suspended for one year (until November 2026). They may resume upon expiry; cross-period shipments require risk assessment.
Q: What if I don’t know whether my product is controlled?
A: First check HS code regulatory conditions, then cross-reference the dual-use items list. When uncertain, consult MOFCOM or engage professional customs brokers/law firms β do not “take a gamble.”
V. Further Reading
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