China's export control regime has expanded significantly since 2020. Whether you're exporting technology to China or transferring controlled items out of China, you need to understand the rules—and the risks of non-compliance.
China's export control system has evolved from scattered regulations into a comprehensive framework. The cornerstone is the 2020 Export Control Law, supplemented by sector-specific rules.
Comprehensive framework covering dual-use items, military products, nuclear materials, and other controlled goods and technologies.
出口管制法
China's response to US Entity List. Companies can be blacklisted for endangering China's sovereignty or discriminating against Chinese entities.
不可靠实体清单
Catalog of technologies restricted or prohibited from export, recently updated to include AI-related technologies.
中国禁止出口限制出口技术目录
Counter-measures against foreign sanctions, potentially requiring companies to ignore US/EU export controls in certain cases.
阻断外国法律与措施不当域外适用办法
Companies operating in both the US/EU and China face potential conflicts between Western and Chinese export controls. Compliance with one jurisdiction's rules may violate another's. We help you navigate this complex terrain.
"Dual-use" items have both civilian and potential military applications. China's dual-use control list closely mirrors international Wassenaar Arrangement categories but includes China-specific additions.
China's 2020 technology catalog updates added restrictions on AI algorithms, drone technology, and certain data processing technologies. These restrictions affect both outbound transfers and technology sharing with foreign parties.
Understanding which list(s) apply to your products or technology is the first step in compliance.
Commercial goods and technologies that could have military applications. Covers materials, equipment, software, and technical data.
Examples: High-performance computing, certain chemicals, precision machine tools, encryption software, carbon fiber materials.
Weapons, munitions, and military equipment. Strictly controlled with few exceptions.
Examples: Firearms, explosives, military vehicles, certain optics and targeting systems.
Nuclear materials, equipment, and related technologies. Subject to international treaty obligations.
Examples: Uranium, nuclear reactor components, certain isotope separation equipment.
Chemical weapons precursors and certain industrial chemicals with potential dual-use applications.
Examples: Certain phosphorus compounds, fluorine compounds, specific acids and agents.
Pathogens, toxins, and related genetic materials with potential bioweapons applications.
Examples: Certain viruses, bacteria, genetic sequences, delivery equipment.
Items related to missile and rocket development, including components and guidance systems.
Examples: Rocket motors, guidance systems, certain alloys, propulsion components.
When your items fall under control lists, you need an export license. Here's the process:
Determine if your item is controlled and under which list/category
Verify the recipient isn't on restricted lists or diverting items
Submit license application to MOFCOM with required documentation
MOFCOM reviews (45 days standard, may involve other agencies)
License granted, denied, or conditional approval with restrictions
Export license application • End-user certificate • End-use statement • Technical specifications • Contract or order details • Corporate registration • Previous export records (if applicable)
An Internal Compliance Program (ICP) is increasingly expected—and in some cases required—for companies dealing with controlled items. A good ICP also provides a defense if violations occur.
Documented export control policies approved by senior management.
Clear roles and reporting lines for compliance.
Procedures to evaluate every export transaction.
Regular education for all relevant personnel.
Regular assessment of compliance effectiveness.
Documentation requirements and retention.
Determine which (if any) control lists apply to your products, technology, or software. We provide defensible classification opinions you can rely on.
Prepare and submit export license applications to MOFCOM. We handle documentation, respond to queries, and track approvals.
Build or enhance your Internal Compliance Program. We create practical, auditable procedures tailored to your business.
Train your team on China export control requirements, red flags, and compliance procedures. Available in English and Chinese.
Navigate conflicts between Chinese and Western export control requirements. Develop compliant strategies for multi-jurisdictional operations.
Stay ahead of changes to control lists, entity lists, and enforcement trends. We alert you to developments affecting your business.
Export control violations carry severe penalties—including criminal liability. Don't leave compliance to chance.
Get Expert Guidance