In the export control regulatory system, the control list, as a key component, plays a crucial role in regulating export activities and safeguarding national security and interests. The control list is mainly divided into the special item control list and the special entity control list. Among the special item control list, the “dual-use item” control list has become the focus of export control work due to its wide application scope and complex regulatory requirements.
According to Article 2 of the “Regulations of the People’s Republic of China on the Control of Dual-Use Items Export” (hereinafter referred to as the “Regulations on the Control of Dual-Use Items Export”), dual-use items refer to goods, technologies, services and related technical data that have both civilian and military uses, or can enhance military potential, especially those that can be applied in the design, development, production or use of weapons of mass destruction and their means of delivery. This definition not only clarifies the dual-use nature of dual-use items but also emphasizes the risk that they may be used to manufacture weapons of mass destruction. At the same time, the regulations also stipulate that the export control of other items related to maintaining national security and interests and fulfilling international obligations such as non-proliferation as stipulated in Article 2 of the Export Control Law shall also apply to the export control of dual-use items.
Common dual-use items include: 1. Chemicals: such as ether, hydrochloric acid, sulfuric acid and other chemicals that can be used to make drugs, which are widely used in the medical and chemical industries and may be used to produce drugs or chemical weapons; 2. Materials: such as special steel, carbon fiber and other high-performance materials, which are important in the aerospace, automotive manufacturing and other civilian fields as well as in the manufacture of military equipment; 3. Equipment: such as high-pressure water cannons, suction dredgers, etc., which play important roles in both civilian and military fields; 4. Technologies: such as certain advanced manufacturing technologies and information technologies, which can promote economic and social development in civilian fields and enhance the combat capabilities of weapons and equipment in military fields.
The export control list for dual-use items mainly consists of two categories: the export control list for dual-use items and the list of temporarily controlled dual-use items.
1. Export Control List for Dual-Use Items
According to the relevant provisions of the Export Control Law and the Regulations on the Export Control of Dual-Use Items, the Ministry of Commerce, the Ministry of Industry and Information Technology, the General Administration of Customs, and the State Cryptography Administration jointly announced the “Export Control List for Dual-Use Items of the People’s Republic of China” (hereinafter referred to as the “Dual-Use Items Control List”) on November 15, 2024. This list will come into effect on December 1, 2024. Dual-use items listed in this list are subject to long-term control measures.
When exporting items on the Dual-Use Items Control List, operators must apply for a license from the national export control authority. Only after obtaining the license can they export the listed items. The national export control authority will review the exporters to ensure their export activities comply with laws, regulations, and the list requirements. At the same time, it will also track and verify the end users and end uses of the exported items to prevent them from being used for illegal activities.
2. Temporarily Controlled Dual-Use Items
According to the Regulations on the Export Control of Dual-Use Items, to safeguard national security and interests and fulfill international obligations such as non-proliferation, with the approval of the State Council or the approval of the State Council and the Central Military Commission, the competent department of foreign trade under the State Council may implement temporary control over goods, technologies, and services not listed in the export control list for dual-use items and make an announcement. The implementation period of temporary control shall not exceed two years each time.
Before the expiration of the implementation period of temporary control, an assessment shall be conducted in a timely manner, and the following decisions shall be made based on the assessment results: if no longer necessary to implement control, the temporary control shall be lifted; if control needs to continue but it is not appropriate to include in the export control list for dual-use items, the temporary control shall be extended, with an extension not exceeding two times; if long-term control is needed, it shall be included in the export control list for dual-use items.
In addition to the above-mentioned control list for dual-use items, our country also has corresponding control lists for other items, including: “Military Product Export Management List”, “Catalogue of Technologies Prohibited from and Restricted for Export in China”, “Export Control List for Biological Dual-Use and Related Equipment and Technologies”, and “Export Control List for Certain Chemicals and Related Equipment and Technologies”. These lists respectively list the controlled items and technologies in the fields of military products, technology, biological dual-use, and chemicals, along with corresponding control measures.
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Post time: Jul-20-2025