China to Implement New Dual-Use Export Control Regulations (From Sandler Travis and Rosenberg)
China’s export control law was first implemented in December 2020, and Beijing has now announced a detailed implementation rule that will become effective Dec. 1. Under these Dual-Use Export Control Regulations, the overall dual-use good control mechanism and the export license application process will remain unchanged, but other restrictions will impact U.S. companies that rely on importing subject goods from China and their Chinese subsidiaries. Additional information is expected to be announced in the near future…
Highlights of the new rules include the following.
– The timeline for processing export license applications will remain 45 working days.
– China is expected to update its dual-use item control list before Dec. 1. Unlike the U.S. ECCN classification system, China’s current control list is based on HS code and product description, with temporary control measures and catch-all controls if there is a national security concern.
– Unlike the U.S. and many other countries, China does not have a white list of countries for exports of dual-use goods; if a product is classified as such in China, the exporter must apply for a license before export. For more information, please go to