由 caicai8478 I. Comparison of drone export control policies between China and the United States
(I) China’s drone export control policy
Current regulatory system:
“Export Control Law of the People’s Republic of China” (implemented in 2020)
“Catalogue of Import and Export Licenses for Dual-Use Items and Technologies”
Specific drone technologies are included in the “Catalogue of Technologies Prohibited and Restricted from Export in China”
Control focus:
Drone with a flight time of more than 1 hour
Drone with a maximum take-off weight of more than 7kg
System with autonomous flight control and target recognition capabilities
Drone with a payload capacity exceeding a certain standard
Licensing system:
Dual-use export license issued by the Ministry of Commerce
Required Through end-user and end-use review
(II) U.S. drone export control policy
Legal framework:
Export Control Reform Act (ECRA)
International Traffic in Arms Regulations (ITAR)
Commerce Control List (CCL) of the Bureau of Industry and Security (BIS) of the Department of Commerce
Control features:
Including some military-grade drones in the USML
Strict review of “dual-use” drones
“Entity List” restrictions on Chinese companies
Embargo on specific countries
Latest developments:
Expanding the scope of restrictions on Chinese drone technology in 2023
Strengthening end-user monitoring requirements
II. Analysis of key differences between Chinese and U.S. policies
Comparative dimensions Chinese policy U.S. policy
Control concept Balance between national security and development Maintenance of technological hegemony
List scope Clearly list technical parameters Broad definition + case explanation
Licensing process Approval within 60 working days May take up to 120 days
Enforcement focus End-use verification Full supply chain review
International cooperation Participation in multilateral mechanisms Unilateral sanctions are the main ones
III. Compliance logistics solutions
(I) Compliance preparation before export
Product classification assessment:
Establish an internal technical parameter assessment matrix
Employ a third-party compliance consultant for double confirmation
Document system construction:
Develop a standardized export compliance document package (including ECCN classification report, end-user statement, etc.)
Establish a product technical archive management system
(II) Construction of special logistics channels
Regional logistics center layout:
Establish a transit warehouse in policy-friendly regions (such as Southeast Asia)
Implement modular transportation (separate sensitive components)
Customized transportation solutions:
Sensitive technology: Use “door-to-door” dedicated line service
Ordinary products: Use free trade zone policies to reduce compliance costs
Establish an emergency logistics plan (including return processing procedures)
(III) Application of digital compliance tools
Blockchain traceability system:
Achieve visual tracking of the entire supply chain
Automatically identify changes in the control list and issue warnings
Intelligent compliance platform:
Integrate the control list database of various countries
Provide real-time regulatory updates and case analysis
IV. Recommendations for corporate responses
Establish a dual-track compliance system:
Establish professional compliance teams in China and the United States
Conduct quarterly policy gap analysis
Supply chain resilience management:
Develop a multi-source supplier certification system
Maintain a 6-month safety inventory of key components
International cooperation path:
Explore the joint R&D model of the “technological neutral zone”
Participate in the formulation of international standards to reduce compliance conflicts
Talent training plan:
Regularly organize cross-border compliance training
Establish an expert think tank support system
V. Outlook for future trends
Technical standard competition will intensify regulatory differentiation
Third-party countries may become a new regulatory game field
The application of artificial intelligence in export compliance will expand
Green technology exemptions may become a new negotiation topic
Enterprises should establish a dynamic monitoring mechanism to transform compliance management from a cost center to a competitive advantage and achieve steady development in a complex international environment.