China Dual-Use Control List

The list is a dated official catalogue — classify against the version in force on the shipment date.

MOFCOM and cooperating agencies publish and revise China’s dual-use export-control list. Entries are technical. Exporters should keep a classification memo that cites the list version, the entry, and why the item is in or out. Temporary controls (for example on specific minerals or technologies) can appear as announcements outside the main book. Customs will ask for the licence if the list says so. Use the tracker and official notices, then the licence Quick Answer if you are in.

The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

Which list version applies to this shipment?

Publication date vs bill of lading date.

Version

Which entry, if any, matches the specs?

Parameters, purity, software functions — not the marketing name.

Entry

Is there a temporary or mineral-specific control?

Announcements can sit beside the main list.

Temp

Who signed the classification?

A named person and date, not a vendor slogan.

Memo

Working rule: MOFCOM and cooperating agencies publish and revise China’s dual-use export-control list. Entries are technical.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal

Ask the operating question

Why it changes the route

Stale annex

Is the team using a 2020 PDF?

The live list has moved more than once.

Temporary control

Did a recent notice cover this mineral or tool?

It may not yet sit in the bound catalogue you bookmarked.

No memo

Is ‘not listed’ only in a WeChat?

You cannot defend that to customs or MOFCOM.

Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Official list extractThe entry and the announcement date you relied on.

02Specs vs entryWhy the item meets or misses the technical note.

03Temporary noticesAny mineral or tech announcement in the same window.

04Classification memoAuthor, date, shipment or deal ID.

Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Is the dual-use list the only China control list?

No. Military, nuclear and some technology-export catalogues and notices also exist. Start with dual-use, then check the others that fit the item.

Can a freight forwarder classify for us?

They can help on HS. Control-list classification is the exporter’s duty. Keep it in-house or with counsel.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.

MOFCOM

GACC (Customs)

PRC Export Control Law (gov.cn)

National laws database (NPC)