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On June 16, 2025, the General Administration of Customs of China (GACC) issued the Announcement on Customs Inquiries Regarding Export Control of Dual-Use Items (GACC Announcement No.123 of 2025), which took effect immediately.
Export control scope
Dual-use items, in the Catalogue of Dual-use Items and Technologies Subject to Import and Export Licensing (2025), that are subject to export licensing requirements, including:
Dual-use items listed in the Export Control List of Dual-use Items, covering but not limited to:
Rare earth elements (such as samarium, gadolinium, terbium, etc.)
Graphite and its products (including artificial graphite materials and products, natural flake graphite and its products, etc.)
Metal powders of various metals or their alloys (such as zinc, titanium, magnesium, etc.)
Systems, equipment, and components used for testing, inspection, and production.
Nuclear items and related technologies
Precursor chemicals
Precursor chemicals restricted to be exported to specific countries (e.g., Laos, Burma, Afghanistan)
Enterprises handling goods subject to export control for dual-use items shall obtain an export permit from the Ministry of Commerce before export.
Customs inquiry
According to the GACC Announcement No.123 of 2025, when there is evidence indicating that the exported goods may fall within the export control scope, but no permit issued by the authority is provided, the customs will issue a Notice of Customs Inquiry on Export Control of Dual-Use Items to the exporter. The exporter shall submit the required materials (e.g., testing report, explanatory statement) to the customs within 7 days from the date receiving the notice. If the materials are in a foreign language, a Chinese translation shall also be provided.
Customs inspection and determination
Upon receipt of the materials submitted by the exporter, customs shall make a determination or initiate an identification process based on the following circumstances, subsequently issuing a Notice of Inquiry/Identification Results for Export Control of Dual-Use Items:
If it is determined that no dual-use item permit is required, the enterprise will be notified to proceed with the necessary subsequent procedures.
If it is determined that a dual-use item permit is required, the goods will not be released and will be managed in accordance with regulatory guidelines.
If it cannot be determined whether the goods are classified as dual-use items, customs will submit an identification request to the national export control authority and proceed based on the identification conclusion.
Notably, during the identification or inquiry period, customs will withhold the release of the relevant goods.
