China Issues Dual-Use Export Control List

China’s Ministry of Commerce released its new dual-use export control list Nov. 15 ahead of the Dec. 1 effective date for its recently issued dual-use export regulations, which outline how the ministry will approach dual-use licensing and export enforcement, detail possible extraterritorial impacts of the controls, and more (see 2410210042).

The list consolidates controlled items into various categories and assigns each item an export control code composed of five numbers and letters, according to an unofficial translation of the list, similar to Export Control Classification Numbers under the Commerce Department’s Commerce Control List. The first character represents the item’s industry field, the second character represents the item type, the third character represents the reason why the item is controlled, and the fourth and fifth characters are used for “item sorting,” the ministry said.

Jose Rodriguez, a Bureau of Industry and Security senior export control officer in Beijing, said on LinkedIn that the list doesn’t yet introduce any new export controls -- it only consolidates existing controls into a new format. But he also said: “I would expect that more controls are added in the future.”