New trends in the control of dual-use items: Corporate compliance is urgent!

The recent export control measures for dual-use items implemented by the Ministry of Commerce against Taiwan mark that my country's export control system has entered a new stage that is deeply bound to national sovereignty and security interests. On July 9, 2025, the Ministry of Commerce of China issued Announcement No. 35, which clearly listed 8 Taiwan entities on the Export Control List for the first time, and implemented a comprehensive embargo in accordance with the "Export Control Law" and the newly implemented "Dual-Use Items Export Control Regulations". In this context, relevant enterprises must deeply understand the policy intent, accurately grasp compliance requirements, and quickly improve prevention and control capabilities. This is a problem that enterprises must solve at present. This article will analyze the core connotation of the latest regulatory developments and provide practical compliance path guidance for enterprises.

一、Latest regulatory developments

（1）On July 9, 2025, the Ministry of Commerce of China issued Announcement No. 35

Eight Taiwanese entities, including Hanxiang Aviation Industry Co., Ltd. and Sun Yat-sen Institute of Science and Technology, have been included in the export control list, and the export of any dual-use items to them will be prohibited from now on. The announcement requires that all ongoing related export activities must be stopped immediately, and special applications must be made to the Ministry of Commerce separately.

（2）On April 9, 2025, the Ministry of Commerce of China issued Announcement No. 22 of 2025

Add 12 U.S. entities including U.S. Photonics to the export control list. The export of dual-use items to the above-mentioned 12 U.S. entities will be prohibited from April 10; ongoing related export activities should be stopped immediately. If export is really necessary under special circumstances, the export operator shall apply to the Ministry of Commerce.

（3）On April 4, 2025, the Ministry of Commerce and the General Administration of Customs of China issued Announcement No. 18 of 2025

The decision to implement export controls on some #Medium and Heavy Rare Earth-related items includes samarium-related items, gadolinium-related items, terbium-related items, dysprosium-related items, scandium-related items, and yttrium-related items. Export operators exporting the above-mentioned items shall apply for permission from the commerce department of the State Council in accordance with the relevant provisions of the "Export Control Law of the People's Republic of China" and the "Regulations of the People's Republic of China on the Export Control of Dual-Use Items". In addition, export operators should strengthen the identification of items. When declaring customs, they should indicate whether they are controlled items in the remarks column. If they are controlled items, they should list the export control code of dual-use items.

（4）On April 4, 2025, the Ministry of Commerce of China issued Announcement No. 21 of 2025

16 U.S. entities including High Point Aviation Technology Corporation have been included in the export control list. From now on, exports of dual-use items to the above 16 U.S. entities will be prohibited; ongoing related export activities should be stopped immediately. If export is really necessary under special circumstances, the export operator shall apply to the Ministry of Commerce.

二、Full process guide for export licenses for dual-use items

1. Qualification preparation and item identification

Enterprises need to have import and export qualifications, and if they involve special items, they need to be registered with the commerce department as an "export control responsible entity." Establishing an internal compliance system is the basis for application, and it is recommended to designate a professional team to be responsible for the entire process management.

The critical first step is to accurately identify controlled items:

Compare with the "Catalogue for the Administration of Import and Export Licenses for Dual-Use Items and Technologies" (available on the official website of the Ministry of Commerce)

With the help of China Export Control Information Network database (http://exportcontrol.mofcom.gov.cn/)

Entrust a professional testing agency to conduct item parameter identification

Case tip: A company exported graphite products. After testing, it was found that the purity reached the standard for nuclear reactor moderators. It should apply for a license in time to avoid violations.

2. List of core application materials

According to the Dual-Use Items Export Control Regulations, required materials include:

3. Things to note when filing online

Log in to the unified platform of the Ministry of Commerce’s business system and apply for an electronic corporate key;

The end use description must be specific (e.g. "for the production of refractory bricks" rather than "industrial use").

The quantity units of items are uniformly converted into kilograms (if the contract uses other units, a conversion explanation must be attached).

三、Key points of corporate compliance strategies and risk avoidance

1. Make use of “general license” to improve efficiency

For enterprises that export dual-use items stably in the long term, they can apply for a #general license with a validity period of no more than 3 years, exempting them from the burden of application on a case-by-case basis. Conditions to be met include:

✅ A well-established and functioning internal compliance system for export controls

✅Have export records (more than two years (inclusive)), apply for more than 40 dual-use item export licenses for more than two consecutive years (inclusive), have fixed export channels and end users

✅ Have not received criminal punishment or administrative punishment from relevant departments in the past 3 years

Additional materials list:

Instructions for operating the internal compliance system.

Instructions on license application and use.

Export channels and end-user instructions.

2. Enterprises should investigate transaction partners

Understand whether the transaction object is on the sanctions list, whether the transaction involves controlled items and technologies, etc., and file the information after feeding back the results.

3. Enterprises establish internal compliance systems for export control

Enterprises need to conduct comprehensive risk assessments, take timely response measures, regularly review export-controlled products, follow up on the latest developments, understand export policies, and update compliance systems in a timely manner.

With the implementation of the "Control List" system in the "Regulations on the Export Control of Dual-Use Items" in 2024, and the country's firm stance on core interest issues, the compliance environment faced by relevant companies will become more complex and severe. Dynamic adjustments to the list, stricter review standards, and a sharp increase in the cost of violation will become the norm. In this context, companies urgently need to abandon the mentality of taking chances and deeply embed export control compliance capabilities into the core of the strategic layout of the global supply chain.

Our company has a deep understanding of national policy orientation and corporate compliance pain points, and relying on a professional team, we are committed to providing enterprises with dual-use item solutions covering the entire life cycle:

✅Accurate item judgment and risk screening

✅Efficient compliance material preparation and system declaration

✅Customized internal compliance system construction and training

✅Continue to track policy updates and list updates. Let us join hands to cope with the changes and help your global trade voyage to brave the wind and waves and move forward steadily while maintaining national security and interests.