由 caicai8478 I. Definition and Classification of Sensitive Goods
Sensitive goods usually refer to goods and technologies that may involve national security, foreign policy, economic interests or international obligations, mainly including the following categories:
Dual-use items: Dual-use goods and technologies that can be used for both civilian and military purposes
Strategic materials: Energy, minerals, food and other goods related to national economic security
Controlled technology: Key technologies in the field of high-tech
Restricted export goods: Goods restricted by international conventions or domestic regulations
Sanction-related items: Goods involving sanctioned countries, organizations or individuals
II. Key steps to identify sensitive goods
- Commodity code (HS code) verification
Verify the HS code of the commodity against the “Tariff of the People’s Republic of China”
Pay special attention to the HS code in the export control list (such as the “Catalogue of Dual-use Items and Technology Import and Export License Management”)
Update the HS code database regularly to ensure that the latest version is used
- End-use analysis
Understand the buyer’s background and end-user information
Evaluate whether the end-use of the goods may involve military or sensitive fields
Beware of “middlemen” or vague end-use descriptions - Destination country risk assessment
Verify whether the export destination belongs to a sanctioned country or region
Understand the political environment and international relations of the destination country
Pay attention to the special regulatory requirements of high-risk countries
- Technical parameter evaluation
Detailed analysis of the technical specifications and performance parameters of the goods
Compare with the technical indicators in the control list (such as accuracy, speed, strength, etc.)
Pay special attention to technical features that can be used for weapons research and development or military purposes
III. Practical verification tools and methods
Official list comparison method:
Ministry of Commerce “Dual-use Items and Technology Import and Export License Management Catalogue”
“China’s Prohibited Export and Restricted Export Technology Catalogue”
“Export Control Regulations” supporting control list
Online query tool:
China International Trade “Single Window” Export Control Query System
Website of the Ministry of Commerce’s Industrial Security and Import and Export Control Bureau
General Administration of Customs Commodity Classification Decision Query System
Enterprise internal evaluation process:
Establish an export commodity classification evaluation table
Set up a multi-level review mechanism
Regular compliance training and audits
IV. Risk warning signals
Buyer-related signals:
Refuse to provide end-use Information
Request for unusual technical specifications
Unreasonable payment methods
Transaction-related signals:
Purchase ordinary goods at abnormally high prices
Insist on using cash transactions
Request to change the original packaging or labeling of goods
Logistics-related signals:
Request to transfer to high-risk countries
Fuzzy or frequently changing transportation routes
Rejection of standard inspection procedures
V. Compliance recommendations
Establish an internal compliance system:
Establish a full-time compliance position
Develop written compliance policies and procedures
Periodically conduct compliance risk assessments
Professional support channels:
Consult professional trade lawyers or compliance consultants
Participate in compliance training organized by the commerce department
Maintain good communication with customs and commerce departments
Document retention requirements:
Keep complete transaction records for at least 5 years
Retain documents on the compliance review process
Establish a traceable archive management system
VI. Common problem handling
What if you are not sure whether it is sensitive?
Apply to the Ministry of Commerce’s Industrial Security and Import and Export Control Bureau for pre-confirmation of commodity classification
Consult through the customs 12360 hotline
Entrust a professional organization to conduct compliance assessments
What if you find that the exported goods may be sensitive?
Immediately stop subsequent shipments
Voluntarily disclose to the competent authorities
Cooperate with investigations and take remedial measures
Through the above systematic identification methods and compliance measures, enterprises can effectively reduce compliance risks in export trade and avoid administrative penalties, economic losses and damage to reputation caused by violations.