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.

01

What exact form are you exporting?

Determine whether the shipment is metal, compound, wafer, epitaxial material or gallium-containing product.

Form
02

What does the current China notice say?

Match compound, purity and semiconductor parameters to the current gallium control entry and licensing consequence.

Notice
03

Who is the end user and what is the end use?

Catch-all can still apply if unlisted.

End
04

Do foreign lists also apply?

Destination-state mineral and dual-use rules.

Stack

Working rule: Gallium metal, compounds and some related items have been subject to China export licensing announcements used as a dual-use/strategic control.

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 brochure
Are sales still quoting last year’s ‘uncontrolled’ line?
Notices have changed; re-read before the booking.
Compound vs metal
Is the SKU gallium metal, oxide, or a wafer-related input?
The notice’s technical note, not the marketing name, decides.
Technology not metal
Is the export know-how or equipment rather than the commodity?
Technology-export catalogues can apply even when the metal shipment looks different.
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.

01Product identityRecord compound, purity and semiconductor parameters, CAS or HS claims, technical datasheets and the product's actual function.
02Current notice extractDated MOFCOM/GACC text you relied on.
03End-user/end-useWho uses it and for what.
04Tracker checkRecord the official source and date used to verify the gallium control position for this SKU.
Common confusions

Questions people ask before they build.

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

Did the 2023 headlines freeze the rule forever?

No. Treat gallium as a living control. Re-read the current announcement and any later dual-use list updates.

Where do we see if the control moved?

The China export-control tracker and official MOFCOM/GACC notices. Do not use this Quick Answer as a substitute list.

Primary authorities

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

PRC Export Control Law (gov.cn)
MOFCOM
GACC (Customs)
National laws database (NPC)