由 caicai8478 China’s export control list aims to safeguard national security and development interests, fulfill international obligations, and implement reasonable control over sensitive materials. The following is an analysis of sensitive materials in China’s current export control system, combined with the Export Control Law (2020) and the latest control catalog:
I. Legal basis
Export Control Law (effective on December 1, 2020)
China’s Catalogue of Prohibited and Restricted Export Technologies (revised in 2020)
Catalogue of Dual-Use Items and Technologies Import and Export License Management (jointly issued by the Ministry of Commerce and the General Administration of Customs)
II. Main categories of sensitive materials
(I) Dual-use items (military and civilian)
Nuclear materials and equipment
Nuclear reactor components, uranium enrichment centrifuges, radiation detection equipment
Strictly controlled by the Nuclear Export Control Regulations
Chemicals and biological agents
Chemicals included in the monitoring list of the Chemical Weapons Convention (such as thiodiglycol)
Highly toxic pathogens (such as Ebola virus strains)
Material processing technology
High-strength metals (tungsten alloys, titanium alloys, etc.) and their production technology
High-temperature resistant composite materials (used in the aerospace field)
Electronics and communications
Supercomputing related technologies (chips with floating-point computing capabilities ≥ 8TFLOPS)
Quantum encryption communication equipment
Semiconductor manufacturing equipment that meets the parameters of the Wassenaar Agreement
(II) Military supplies
The “Military Export Management List” covers:
Guided weapon systems and components
Armored vehicles, ship propulsion systems
Military encryption equipment (AES-25 6 and above)
(III) Emerging technology fields
Artificial intelligence
Specific training algorithms for autonomous driving neural networks
Face recognition systems (recognition accuracy ≥ 99% and support for large-scale monitoring)
Aerospace
Rocket fuel formula (propellant with specific impulse ≥ 245s)
High-resolution satellite imaging system (ground resolution ≤ 0.3m)
Advanced manufacturing
Extreme ultraviolet lithography (EUV) related technologies
Topology optimization software for metal 3D printing
(IV) Resource commodities
Rare earth products: NdFeB permanent magnets (neodymium content ≥ 99%)
Graphite materials: high-purity (≥ 99.9%) flake graphite
III. Analysis of regulatory characteristics
Technical threshold Value control: Most items have clear performance parameter thresholds
End-user review: Exporters are required to verify the buyer’s end use
Dynamic adjustment mechanism: Update the control list every year (such as adding superconducting materials in 2023)
IV. Corporate compliance recommendations
Regularly check the latest version of the “Dual-Use Items Catalog” (updated on the Ministry of Commerce’s official website)
Establish a classification and evaluation process for export items (it is recommended to refer to the HS code and ECCN comparison table)
Prepare complete technical description documents (including end-user commitment letters) when applying for export licenses
Note: The determination of specific items needs to be combined with the customs commodity code and technical parameters. It is recommended to conduct intelligent inquiries through the “China Export Control Compliance Service Platform” (official website). The export license approval cycle for items with higher sensitivity may be as long as 60-90 working days.