After a 16-year hiatus, China’s steel product export license system was officially reinstated on January 1, 2026. Covering 300 HS codes spanning the entire industry chain from steel, pipes to coils, export enterprises must apply for licenses with export contracts + quality inspection certificates. This is a major policy change that cross-border e-commerce and traditional foreign trade enterprises must address.
I. Policy Quick Reference
| Element | Details |
|---|---|
| Regulatory Basis | MOFCOM 2025 Announcement No. 79 |
| Legal Foundation | Foreign Trade Law, Regulations on Import/Export of Goods, Measures for Administration of Goods Export Licenses |
| Effective Date | January 1, 2026 |
| Coverage | 300 HS codes covering the entire steel industry chain |
| Application Materials | Export contract + quality inspection certificate issued by manufacturer |
| Issuing Authority | Central SOEs β MOFCOM License Bureau; other enterprises β provincial commerce authorities |
| Historical Background | Abolished in 2009, reinstated after 16 years |
II. Affected Categories
| HS Chapter | Category | Rebate Rate | License |
|---|---|---|---|
| Chapter 72 | Steel (steel products/pipes/coils, etc.) | 0%~13% | π΄ Required |
| Chapters 72-73 | Steel products/semi-finished | 0%~13% | π΄ Required |
| Chapter 73 | Steel articles (fittings/structural parts, etc.) | 0%~13% | π΄ Required |
III. Application Process
- Confirm HS Code β Is it within the 300 license-managed codes?
- Prepare Materials β Export contract + manufacturer quality inspection certificate
- Online Application β MOFCOM License Affairs Bureau unified platform
- Review & Issuance β Central SOEs issued by License Bureau; other enterprises by provincial commerce authorities
- Customs Export Declaration β Declare with license + customs declaration form
IV. Impact on Cross-Border E-Commerce / DDP
| Impact | Explanation |
|---|---|
| Extended shipping cycle | License approval expected to add 3-7 working days |
| DDP cost increase | License application may incur agency service fees |
| Rebate rate differences | Some steel products have 0% rebate; export treated as domestic sale subject to 13% VAT |
| U.S. stacked tariffs | Steel exports to the U.S. also face Section 232 tariffs (up to 50%) + Section 301 tariffs |
| Consequences of unlicensed export | Return/confiscation/fines; severe cases may constitute smuggling |
V. FAQ
Q: I’m exporting stainless steel cutlery (HS 7323). Do I need a license?
A: You need to confirm whether it falls within the 300 HS code catalog. Stainless steel products (Chapter 73), if they are deeply processed end-consumer goods, may not be included; but semi-finished/raw materials are likely covered. Verify item by item against the MOFCOM announcement appendix.
Q: What if the export contract is already signed but the license hasn’t been issued yet?
A: The license must be obtained before customs declaration. It is recommended to initiate the application immediately after contract signing, allowing sufficient time. Central SOE approvals are typically faster than local enterprises.
Q: Does plywood furniture (mainly wood, with minor steel components) require a steel export license?
A: Classify by primary material. If the HS code falls under Chapter 94 (furniture) rather than Chapters 72-73, it is generally not subject to steel license management. However, furniture containing steel structural parts should be verified item by item.
VI. Further Reading
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