The “reiteration” of dual-use item export licenses can be understood as the government’s ”official annual major verification“ conducted at the start of each year. Its purpose is to ensure the latest control requirements align with actual trade practices.
1. Why the Emphasis Now?
● International Situation & Geopolitical Risks: Escalating regional conflicts and tensions have increased the risk of dual-use items being diverted for military purposes. This reiteration aims to prevent Chinese products from being misused or involved in activities violating international obligations.
● Technological Evolution & Regulatory Catch-Up: The line between civilian and military use is becoming increasingly blurred for emerging technologies like artificial intelligence, drones, and high-performance computing, necessitating clearer and strengthened regulatory requirements.
● Warning from Non-Compliance Cases: Recent cases of enterprises violating regulations by neglecting or circumventing license requirements serve as a “wake-up call.” This reiteration aims to heighten corporate compliance awareness.
● Fulfilling International Responsibilities: As a key member of the non-proliferation regime, China demonstrates its commitment as a responsible major power by strengthening export control enforcement.
2.Simplified Analogy: Think of It Like a Hardware Store Selling “Special Tools”
Imagine you run a hardware store. Most tools can be sold freely, but certain special tools (like high-strength cutters, specific chemical agents) can be used for production but could also be modified into weapons.
The government is reminding store owners:
“Please note! For items listed in the ‘Special Tools Catalog,’ you must verify customer identity and intended use, and obtain a ‘Special Sales Permit’ in advance. Recent instances of non-compliant sales have led to items reaching improper channels. Strictly adhere to regulations and conduct thorough self-checks of sales and inventory records.”
● Dual-Use Items: Goods and technologies usable for both civilian and potential military purposes (e.g., specific materials, precision machine tools, drones).
● Export License: A government-issued “permission to export” certificate, which must be applied for and approved before export.
● Reiteration: A high-intensity re-emphasis, reminding enterprises to strictly implement rules and avoid complacency.
3. Application Step-by-Step Guide
（1）Determine if a License is Required
This is the most critical step. Enterprises should self-check against the latest 2026 “Dual-Use Items and Technologies Import/Export License Control Directory.” Note: The core judgment is based on whether the item’s technical parameters and description meet the control list requirements, not solely on the Customs HS code.
● Online Query Tool: Utilize the database on the ”China Export Control Information Website“ for assisted inquiry.
● Official Consultation Channel: If self-assessment is inconclusive, submit a formal business inquiry via the ”Ministry of Commerce Unified Business System Platform,” providing technical specifications and intended use of the item.
（2）Prepare Application Materials
● Basic Documents: Business license, import/export qualifications, contract, end-user certificate, etc.
● Key Documents: Application Form for Dual-Use Items and Technologies Export License, End-User Statement (committing to non-military use).
（3）Submit the Application
● Submit online via the ”Ministry of Commerce Unified Business System Platform” . Applications are initially reviewed by provincial commerce authorities before submission to the Ministry of Commerce (MOFCOM) for approval.
（4）Review & License Issuance
● Review Timeline: MOFCOM typically makes a decision within 45 working days of accepting an application (may be extended for complex cases).
● License Format: Licenses are currently issued as electronic documents. Enterprises can obtain them from the system upon approval.
● License Usage: The “one license per shipment” system is in effect. Licenses are typically valid for 6 months and must be used within this period.
4. Important Considerations
✅ Plan Ahead: It is advisable to apply 2-3 months in advance to avoid shipment delays.
✅ Declare Truthfully: False information will lead to penalties or even criminal liability.
✅ Stay Updated: Closely monitor the latest announcements from MOFCOM and the General Administration of Customs, as control lists may be dynamically adjusted.
✅ Mind Special Scenarios: Whether it’s exhibits for overseas trade shows, shipped samples, or items sent via mail or carried personally, if they are dual-use items, an export license is equally required. There is no exception for “small quantities or personal use.”
Summary
This reiteration of dual-use item export license requirements is both a compliance alert and a call to action from the government to enterprises amidst a complex international environment and technological change. Enterprises should actively respond, conduct strict self-inspections, and standardize their processes. This safeguards national security, fulfills international obligations, and protects against legal and operational risks.
Compliance Creates Value, Safety Ensures Long-Term Success!
Post time: Jan-05-2026