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Dual-Use Export Controls in China: the Baseline Every Company Needs

Published / last verified：2026-07-14 · Author and verification owner：Zhengdao AI Compliance Research Team · Editorial policy

1. What "dual-use items" are

Direct answer: dual-use items are goods, technology and services with both civilian and military uses, or the potential to contribute to military capability. The current list, control code and actual technical parameters determine classification.

They often look like ordinary industrial products — special-alloy tubing, machine tools, chemicals, graphite materials, drone components or encryption software. Companies need a traceable classification process rather than relying on commercial descriptions or intuition.

2. The framework: one law, one regulation, and the lists

• The Export Control Law (2020) is the basic statute — it establishes control lists, the licensing system, end-user and end-use management, and extraterritorial application.
• The Regulations on Export Control of Dual-Use Items (published 2024) is the current core administrative regulation. It repealed the older special regulations on nuclear dual-use items, biological dual-use items and missile-related items, as well as the Measures on Export Control of Certain Chemicals and Related Equipment and Technologies. Manuals that still treat those documents as current core authority need review.
• Control lists and announcements change continuously, and a later instrument can suspend or modify an earlier one. For example, Announcements 55, 56, 57, 58, 61 and 62 of 2025 are suspended by Announcement 70 until 10 November 2026. A current-status check is therefore as important as finding the original publication.

3. Four things a company must do

1. Classify products against the current control lists to judge whether an item is controlled. When unsure, you may seek a classification opinion from the authorities.
2. Apply for licences before exporting controlled items — "licence before goods".
3. Screen transactions: who the customer is, what the end-use is, what route the goods take — review each shipment and keep records. Note the "catch-all" requirement: even if an item is not on a list, if you know it may be used for weapons of mass destruction and similar purposes, you may not export it.
4. Keep records: file review records, documents and statements so they are traceable.

4. The order of magnitude of a violation

Under the liability provisions of the Export Control Law, exporting controlled items without a licence and similar violations face orders to cease, confiscation of illegal gains, and high fines calculated as multiples of the illegal turnover; in serious cases, revocation of relevant business qualifications; and where a crime is constituted, criminal liability. There is also a cost often overlooked: a violation record enters the credit system and directly affects future licence applications and customs credit ratings — effectively a tax on every future deal.

For exact penalty provisions and amounts, rely on the current official legal text (see sources below).

5. Where to start

If your company has never systematically done export-control compliance, do not try to build a perfect system in one step. Do three things first: (1) run your product list against the current control lists; (2) add a minimal review checklist to each export; (3) designate one person with the power to "stop" a high-risk order. Then consider building a full Internal Compliance Program on the nine elements — see the next article.