China: Implemented Export Control Regulation of Dual-Use Items

On 1 December 2024, the Export Control Regulation of Dual-Use Items came into force. The regulation introduces a licensing requirement for the export of goods, technologies, and services that have both civilian and military applications. The objective is to ensure the safeguarding of national security and compliance with international non-proliferation obligations. In accordance with this framework, exporters are obliged to obtain licenses from the Ministry of Commerce, which require the submission of documentation pertaining to the exports, including information regarding the end-user and the intended use of the exported items. It is the responsibility of exporters to ensure that dual-use items are not diverted for unauthorised purposes. In the event of a violation, penalties may be imposed, including fines and the revocation of licences. The State Council is responsible for formulating and publishing the export control list for dual-use items. Special provisions are made for shipment, transit, and re-exports, and items produced abroad using Chinese technology are also covered.