The first checkpoint of export control is on your own side. First determine whether the item is controlled, then decide whether a license is required, and only then proceed to customs declaration.
The legal framework has three parts
The Export Control Law is the superior law, establishing the basic system and responsibilities for control.
The Regulations on Export Control of Dual-Use Items and the Dual-Use Items Export Control List took effect on December 1, 2024; the regulations and the unified list came into force simultaneously.
The list is the core basis for determination. Companies must check it to confirm whether their products are included.
Mandatory requirements for customs declaration
On April 16, 2026, the General Administration of Customs issued Announcement No. 40 of 2026, adjusting the declaration items for export goods customs declarations.
Key declaration points: for items that are controlled, the "Remarks" column of the customs declaration must state "controlled export item" and include the dual-use item export control code.
For items that are not controlled, state "not a controlled export item."
Another key requirement: cross-border e-commerce declaration lists must not use simplified declaration and must declare the full tariff code.
Special requirements for equipment items
On June 5, 2026, the General Administration of Customs issued Announcement No. 77 of 2026, effective June 30, 2026.
This announcement sets out specific requirements for the declaration of equipment such as lathes, milling machines and grinding machines. Exporters of such equipment must check item by item.
Specific declaration standards are subject to the latest official announcement.
Four common misconceptions
Misconception 1: If a consultation with the competent authority yields a reply of "not a dual-use item," you assume no license is needed. A consultation reply is not a licensing conclusion; the list and statutory procedures still govern in the end.
Misconception 2: Using a reference customs commodity code as the basis for determination. A reference code is only a classification reference, not the sole basis for determining whether an item is controlled.
Misconception 3: "Retrofitting" a license after customs declaration. Controlled items must obtain a license first; retroactive application after declaration is not recognized.
Misconception 4: The final destination country does not match the export license. The final destination country on the license must match the actual one; a mismatch is a violation.
How companies should proceed
Step 1, Identify: check the list and technical parameters to determine whether the item is controlled.
Step 2, Apply: for controlled items, apply to the competent authority for the relevant dual-use item export control certificate.
Step 3, Declare: fill in the control status and control code properly on the customs declaration, and do not use simplified declaration.
Step 4, Verify: the end user, end use and final destination country must all match the license content.
Step 5, Keep records: keep contracts, documents and license files complete for verification.
Pre-shipment self-check list
Have the product's technical parameters been checked against the list item by item?
Have you obtained a written conclusion or internal compliance opinion from the competent authority?
Have the final destination country and end user been verified with the customer and documented?
Has the cross-border e-commerce channel declared using the full tariff code?
