Analysis of China’s Laws and Regulations on the Export of Sensitive

GoodsPolicy Highlights:

Control List: China implements the Export Control Catalogue for dual-use items (military and civilian), chemicals (such as precursors), lithium batteries (UN3480), and biological agents, requiring export licenses.

Impact of the Export Control Law:

A new “end-user verification” clause has been added, requiring logistics providers to record the end use of goods to avoid sanctions risks (such as the logistics chain review in the Huawei incident).

Penalties for Violations: Fines up to 5 million yuan, and those responsible may be held criminally liable.

Case Study: In 2023, a Shenzhen company failed to declare the export of graphene (a controlled new material), resulting in customs detention and placement on the dishonest list.