China’s Dual-Use Export Controls Policy

When purchasing products from China, overseas buyers often focus on price, quality, specifications, lead time, and shipping arrangements. However, there is another issue that is easy to overlook: export control compliance.
A dual-use item is a product, technology, or related item that can have legitimate civilian applications but may also have military, strategic, or other controlled applications.
A product may look ordinary and may have many legitimate civilian applications, yet its export from China may still be subject to dual-use export controls if its technical specifications fall within the applicable control parameters.
This is particularly important for industrial equipment, advanced materials, chemical products, electronic components, drones, optical equipment, and other high-performance products.
Before placing an order with a Chinese supplier, buyers should therefore consider not only whether the supplier can manufacture the product, but also whether the supplier is able to legally export it and handle any required export-control procedures.

Examples of Ordinary-Looking Products That May Require Extra Attention
1.Precision Machinery
Examples include: Five-axis CNC machine tools and high-precision machining centers, Precision grinding machines, Coordinate measuring machines, High-speed milling machines, Carbon-fiber winding machines, Composite-material forming equipment, Certain large industrial centrifuges and fermentation equipment.
These machines can have legitimate civilian applications, such as manufacturing automotive parts, molds, tools, medical products, or industrial components.
However, certain levels of positioning accuracy, repeatability, machining capability, configuration, or other technical parameters may bring equipment within applicable export-control requirements.
For buyers: Ask the supplier to confirm whether the specific model and its technical parameters are subject to China’s export controls.

2.Electronics, Optical Equipment and Drones
Industrial-grade drones
Drones are widely used for: Photography, Agricultural spraying, Mapping, Inspection, Surveying.
Certain performance characteristics—such as payload capacity, range, hovering or positioning accuracy, and other technical specifications—may require export-control review.
High-performance lasers
Industrial lasers are commonly used for: Cutting, Welding, Marking, Manufacturing.
Certain high-power or pulsed laser systems, however, may have applications in military or strategic systems and may therefore require additional compliance review.
High-precision navigation components
High-precision inertial navigation modules, gyroscopes, and certain high-accuracy positioning components can be used in civilian drones, vehicles, surveying equipment, and navigation systems.

3.Advanced Materials and Certain Metals
For example: High-purity graphite and certain synthetic graphite materials, High-performance rare-earth permanent magnets, High-purity gallium and germanium, Gallium arsenide and gallium nitride materials, Certain titanium alloys, Special aluminum alloys, High-purity zirconium, Beryllium-containing materials,High-strength carbon-fiber precursor materials and prepregs.
The specific grade, purity, composition, performance, or other technical characteristics may determine whether a product is subject to export controls.

4.Chemical Products: A Particularly Sensitive Area
Examples: Triethanolamine, Methyldiethanolamine, Hydrogen fluoride, Thionyl chloride, Certain specialty epoxy resins, Certain high-performance structural adhesives, Certain specialty solvents.
Certain chemicals may fall under China’s controlled-chemical or dual-use export-control regimes depending on the substance and applicable regulatory requirements.

5.Some “Small” Products Can Also Be Relevant
Certain smaller commercial products can also require attention if their technical specifications fall within controlled parameters.
Examples include: High-strength carbon-fiber materials, Specialized high-pressure gas cylinders and pressure vessels, Certain precision cutting tools, Certain high-performance carbide tools.

What Overseas Buyers Should Ask Their Chinese Supplier
Before placing an order for a potentially sensitive product, overseas buyers should consider asking the supplier the following questions:
1. Is this product subject to China’s dual-use export controls?
2. Does the specific model or specification meet any controlled technical parameters?
3. Does the product require an export license or other export-control authorization?
4. Is your company able to legally export this product from China?
5. Have you previously handled export licenses for this type of product?
6. Will you need an end-user or end-use statement from us?
These questions can help identify potential problems before production and shipment, rather than after the goods have reached the port.

Written by Victoria