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Home / Logistics Knowledge / Customs, Duties and Compliance / Dual-Use Control List

China's Dual-Use Export Control List, Item by Item

One consolidated list replaced a dozen scattered regulations on 1 December 2024. It runs to 189 control codes across ten industry sectors, and every code carries a threshold that decides whether a shipment needs a licence. This page sets out what sits under each code, the parameter that triggers control, and the notices that have amended the list since.

How the list is built

The catalogue is the Consolidated List of Dual-Use Items Subject to Export Control, published by the Ministry of Commerce with the Ministry of Industry and Information Technology, the General Administration of Customs and the State Cryptography Administration in Notice 51 of 2024. It took effect on 1 December 2024 and folded in the nuclear-related, missile-related, biological and chemical lists plus a dozen earlier announcements.

Every entry carries a five-character code: one digit for the industry sector, one letter for the type of item, one digit for the reason it is controlled, and two digits that only order the entries. Reading the code is often faster than reading the description.

The five characters of a control code, taking 3A201 as the example
PositionMeaningValues
First: sectorIndustry field0 other items; 1 special materials, chemicals, micro-organisms and toxins; 2 materials processing; 3 electronics; 4 computers; 5 telecommunications and information security; 6 sensors and lasers; 7 navigation and avionics; 8 marine; 9 aerospace and propulsion
Second: typeWhat the item isA systems, equipment and components; B test, inspection and production equipment; C materials; D software; E technology
Third: reasonWhy it is controlled0 conventional weapons; 1 weapons of mass destruction delivery systems; 2 nuclear non-proliferation; 3 chemical and biological weapons; 4 scheduled chemicals; 5 temporary control; 9 other national security factors
Fourth and fifthSequence numberOrdering only. Sub-items are added with lowercase letters and digits, as in 1C111.b.2 or 2B350.g
The reason digit matters commercially. Codes ending in 5 are temporary controls, which is where most of the recent additions land, and they are the entries most likely to move again. Codes ending in 9 are the national-security catch-all, covering items such as gallium, germanium, antimony, graphite and rare earths that have no weapons convention behind them.

A licence is issued by the Ministry of Commerce, not by customs. Where an entry carries no licence and the goods look close to a controlled parameter, customs issues a written query and holds the cargo; the procedure and its deadlines are set out in our guide to the query and assessment process.

The ten sectors at a glance

What the 189 codes cover
SectorCodesWhat is inside
1 Special materials and chemicals74Propellants, explosives, nuclear materials, biological agents and toxins, scheduled chemicals, rare earths, high-performance fibres and alloys, and the equipment and technology to make them
2 Materials processing35Machine tools, isostatic presses, furnaces, balancing machines, measuring systems, robots, chemical and biological production equipment, synthetic diamond presses
3 Electronics21Analogue-to-digital converters, capacitors and accelerators, frequency converters, power supplies, switches, detonators, mass spectrometers, and the gallium, germanium, antimony and indium families
4 Computers4High-performance computers, ruggedised machines, missile design computers and their software
5 Telecommunications and information security7Encryption hardware, cryptanalysis equipment, telemetry, and the test and production equipment for them
6 Sensors and lasers14Radiation-hardened detectors, photomultipliers, high-speed cameras, lasers, velocity interferometers, pressure sensors, bismuth and tellurium materials
7 Navigation and avionics12Accelerometers, gyroscopes, autopilots, gyro-compasses, navigation processors, altimeters and their test rigs
8 Marine1Dredgers and, since October 2026, dredger pumps, drag heads and cutter heads
9 Aerospace and propulsion15Unmanned aircraft and their engines, payloads and radio links, jet and ramjet engines, turbine manufacturing equipment, wind tunnels, structural composites
0 Other items6High-pressure water cannon, counter-drone systems, tooling for spacesuit visors

Almost every entry is written as a threshold rather than a product name: positioning accuracy in micrometres, purity in percent, energy density in Wh/kg, magnetic performance, temperature tolerance. That structure is deliberate. It means a product name proves nothing, and the datasheet decides. The tables below give the parameter that actually triggers control, so a shipper can put a figure next to each one.

Sector 1: special materials, chemicals, micro-organisms and toxins

This is the largest sector by far, and the one that generates most of the awkward questions at the port, because it mixes weapons-grade material with ordinary industrial chemicals. Forty-one of the seventy-four codes sit in the materials group, eighteen in production and test equipment, and eleven in software and technology.

Components and structures (1A)

CodeItemControl criteria
1A202Tubular composite structuresInternal diameter 75 to 400 mm, made from the carbon or aramid fibre of 1C210.a or from resin-impregnated carbon fibre of 1C210.c
1A225Platinum-coated isotope exchange catalystsDesigned or prepared for hydrogen and water isotope exchange, for tritium recovery from heavy water or for heavy water production
1A226Packing for heavy water separationPhosphor-bronze gauze with chemically treated wettable surface, designed for vacuum distillation columns
1A227High-density radiation shielding windowsCold area greater than 0.09 m2, density greater than 3 g/cm3, thickness 100 mm or more, plus frames designed for them

Production and test equipment (1B)

CodeItemControl criteria
1B003Tooling for superplastic forming and diffusion bondingDesigned for titanium, aluminium and their alloys, for aircraft or spacecraft structures, engines and parts designed for them
1B101Composite part production equipmentFilament winding machines on three or more axes, tape laying machines on two or more coordinates, weaving machine attachments, polymer fibre lines, chemical vapour deposition on heated fibre, wet spinning for refractory ceramics, fibre surface treatment, prepreg and preform equipment, moulds and presses
1B102Metal powder equipmentEquipment for producing the atomised or spherical metal powders of 1C111.b in a controlled environment
1B115Propellant production equipmentStorage, preparation, acceptance testing, curing, casting, pressing, machining and pultrusion equipment for liquid and solid propellants of 1C111
1B116Pyrolytic deposition nozzlesSpecially designed nozzles operating at 1300 to 2900 degrees C and 130 to 20000 Pa to decompose reaction gases onto a mandrel or substrate
1B117Batch mixers for solid propellantTotal capacity above 110 litres with at least one off-centre mixing shaft
1B118Continuous mixers for solid propellantTwo or more mixing shafts and an openable mixing chamber
1B119Fluid energy millsFor producing the solid propellant materials of 1C111.b
1B201Winding machines and mandrelsPositioning, winding and coiling programmable on two or more axes, for composite structures or lay-ups, able to wind cylinders of 75 to 650 mm internal diameter and 300 mm or more in length; includes controllers and precision mandrels
1B225Fluorine electrolytic cellsCapable of producing more than 250 g of fluorine per hour
1B226Electromagnetic isotope separatorsTotal ion beam current of 50 mA or more, for one or more ion sources
1B228Hydrogen cryogenic distillation columnsInternal temperature at or below minus 238 degrees C, internal pressure 0.5 to 5 MPa, austenitic 300 series stainless steel of grain size 5 or finer, internal diameter 30 cm or more, effective length 4 m or more
1B229Water-hydrogen sulphide exchange traysWorking pressure of 2 MPa or more, diameter 1.8 m or more, in fine-grain austenitic carbon steel, plus the internal contactors
1B230Potassium amide solution pumpsGas-tight, capacity above 8.5 m3/h, working pressure 1.5 to 60 MPa for concentrated solution or 20 to 60 MPa for dilute solution
1B231Tritium facilities and equipmentPlants for producing, recovering, extracting, concentrating or handling tritium; refrigeration units to minus 250 degrees C with 150 W or more of heat removal; metal hydride storage and purification systems
1B232TurboexpandersOutlet temperature at or below minus 238 degrees C with hydrogen throughput of 1000 kg/h or more
1B233Lithium isotope separation plantMercury amalgam process equipment including exchange columns, pumps and electrolytic cells, ion exchange systems, and crown ether, cryptand and lariat ether chemical exchange systems
1B234Explosive containment vesselsDesigned to fully contain 2 kg TNT equivalent or more, with features that pass diagnostic or measurement data in real time or with delay

Materials (1C)

CodeItemControl criteria
1C004Tungsten heavy alloysTungsten-nickel-iron or tungsten-nickel-copper with density above 17.5 g/cm3, elastic limit above 800 MPa, tensile strength above 1270 MPa and elongation above 8 percent
1C102Pyrolytic carbon-carbon compositesRepeatedly impregnated
1C107Low-permittivity ceramic compositesDielectric constant below 6 across 100 to 10000 Hz
1C108Graphite and graphite productsFine-grain isotropic graphite with density above 1.72 g/cm3, tensile strain 0.7 percent or more and expansion coefficient at or below 2.75 x 10-6 per degree C; artificial graphite above 99.9 percent purity, flexural strength above 30 MPa and density above 1.73 g/cm3; natural flake graphite including spheroidised and expanded forms
1C111Propellants and constituentsLiquid: hydrazine above 70 percent, UDMH, monomethyl hydrazine, mixed amines, nitrogen tetroxide, red fuming nitric acid. Solid: metal powders under 500 micrometres at 97 percent or more of zirconium, boron, magnesium, titanium, uranium, tungsten, zinc or cerium; spherical ammonium perchlorate; spherical aluminium powder; boron slurry above 40 MJ/kg; HMX and RDX; composite propellants; CTPB and HTPB binders; triethylamine igniter
1C117Tungsten and molybdenum for missile partsMolybdenum at 97 percent or more with particles of 50 micrometres or less; solid tungsten of 97 percent or more, tungsten-copper at 80 percent or more, tungsten-silver at 80 percent or more, machinable into cylinders from 120 mm diameter and 50 mm length; ammonium paratungstate, tungsten oxide and tungsten carbide
1C118Titanium-stabilised duplex stainless steelChromium 17 to 26.5 percent, nickel 4.5 to 7 percent, austenite 10 percent or more by volume, as ingots or bars from 100 mm, sheet from 600 mm wide and 3 mm thick, tube from 600 mm outside diameter with 3 mm wall
1C202Aluminium and titanium alloysAluminium alloy tensile strength of 460 MPa or more, titanium alloy 900 MPa or more, as tube or solid cylindrical bar including forgings with outside diameter above 75 mm
1C210Fibre, filament and prepregCarbon or aramid with specific modulus of 1.27 x 107 m or more, or specific tensile strength of 2.35 x 105 m or more; glass with 3.18 x 106 m or more and 7.62 x 104 m or more; prepreg made from them on tows, rovings or tape up to 15 mm wide
1C216Maraging steelTensile strength of 1950 MPa or more; material with all linear dimensions of 75 mm or less is not controlled
1C225Boron-10Enriched above natural abundance, as elemental boron, compounds, mixtures and articles, including scrap and waste
1C226Tungsten for nuclear useTungsten, tungsten carbide and alloys above 90 percent tungsten, as hollow cylinders of 100 to 300 mm internal diameter weighing more than 20 kg
1C227CalciumMetal impurities other than magnesium below 0.1 percent, boron below 0.00001 percent
1C228MagnesiumMetal impurities other than calcium below 0.02 percent, boron below 0.00001 percent
1C229BismuthPurity of 99.99 percent or more with silver below 0.00001 percent
1C230BerylliumBeryllium metal, alloys above 50 percent beryllium, compounds, articles and scrap. X-ray and logging windows, electronic substrates, and emerald or aquamarine beryl are excluded
1C231HafniumMetal, alloys and compounds above 60 percent hafnium, articles, scrap and waste
1C232Helium-3Helium-3, mixtures containing it and products containing it; products holding less than 1 g are excluded
1C233Lithium-6Lithium enriched above natural abundance in lithium-6, including metal, alloys, compounds, mixtures, articles and scrap; thermoluminescent dosimeters excluded
1C234ZirconiumZirconium with a hafnium to zirconium ratio below 1 to 500, alloys above 50 percent zirconium, compounds, articles and scrap; foil of 0.1 mm or less excluded
1C235TritiumTritium with a tritium to hydrogen atomic ratio above 1 to 1000, tritides, mixtures and products, with an exemption below 1.48 x 103 GBq
1C236Alpha-neutron source radionuclidesActinium 225 and 227, californium 253, curium 240 to 243, einsteinium 253 and 254, gadolinium 148, plutonium 236 and 238, polonium 208 to 210, radium 223, thorium 227 and 228, uranium 230 and 232, in elemental form or in compounds and mixtures at 37 GBq/kg or more; products below 3.7 GBq excluded
1C237Radium-226Radium-226, its alloys, compounds, mixtures, articles and any product containing them
1C238Chlorine trifluorideClF3 in any quantity
1C239High explosivesAny explosive or mixture containing more than 2 percent of HMX, RDX, TATB, ADNBF, DADE or FOX7, DNI, DAAOF or DAAF, DATB, DNGU, PYX, DIPAM, DAAzF, TNP or HNS; also any explosive with crystal density above 1.8 g/cm3 and detonation velocity above 8000 m/s
1C240Nickel powder and porous nickelNickel powder of 99 percent purity or more with mean particle size below 10 micrometres, and porous nickel metal made from it; filament powder and single plates of 1000 cm2 or less are excluded
1C241RheniumRhenium, alloys of 90 percent rhenium or more, and rhenium-tungsten combinations of 90 percent or more, as hollow cylinders of 100 to 300 mm internal diameter above 20 kg
1C350Industrial chemicals outside the scheduled listHydrogen fluoride, potassium fluoride, sodium fluoride, sodium sulphide, potassium bifluoride, sodium bifluoride, ammonium bifluoride, diisopropylamine, 2-diethylaminoethanol, 2-chloroethanol and potassium perchlorate
1C351Human, zoonotic and animal pathogens and toxinsFifty viruses including Ebola, Marburg, Lassa, Nipah, Hendra, SARS, MERS, SARS-CoV-2, variola, dengue, yellow fever and highly pathogenic avian influenza; four rickettsiae; nineteen bacteria including Bacillus anthracis, Brucella, Francisella tularensis, Yersinia pestis and Burkholderia; seventeen toxins including botulinum, ricin-equivalent abrin, conotoxins, Shiga toxins, tetrodotoxin, aflatoxins and T-2. Vaccines are excluded; isolates, live cultures and biological material containing them are not
1C353Genetic material and genetically modified organismsGenetic material carrying nucleic acid sequences linked to the pathogenicity of a controlled micro-organism, or coding a controlled toxin or its subunit, and organisms modified to carry them
1C354Plant pathogensThree viruses and viroids including potato spindle tuber viroid and banana bunchy top virus; six bacteria including Xanthomonas and Ralstonia races 2 and 3; eight fungi including Puccinia graminis, Pyricularia oryzae and Microcyclus ulei
1C450Scheduled chemicalsThree schedules covering chemical warfare agents such as sarin, soman, tabun, VX, sulphur and nitrogen mustards and lewisite; precursors including QL, DF, thiodiglycol, pinacolyl alcohol and the phosphonate families; and key raw materials including phosgene, cyanogen chloride, hydrogen cyanide, phosphorus oxychloride, thionyl chloride, potassium and sodium cyanide. Administered with the Scheduled Chemicals Regulation
1C501Tributyl phosphateCAS 126-73-8
1C901Ultra-high molecular weight polyethyleneFibre with breaking strength of 40 cN/dtex or more, initial modulus of 1600 cN/dtex or more, untwisted; and soft unidirectional laminate at 5.3 kg/m2 or less with a V50 of 700 m/s or more against the 1.1 g fragment
1C902Samarium itemsMetal, alloys including samarium-cobalt and samarium-iron, targets, samarium-cobalt permanent magnet material, oxide and compounds, in ingot, block, bar, wire, sheet, rod, plate, tube, granule or powder form
1C903Gadolinium itemsMetal, gadolinium-magnesium and gadolinium-aluminium alloys, targets including gadolinium-iron and gadolinium-cobalt, oxide and compounds
1C904Terbium itemsMetal, terbium-cobalt and terbium-cobalt-iron alloys, targets, NdFeB permanent magnet material containing terbium, oxide and compounds
1C905Dysprosium itemsMetal, dysprosium-iron and terbium-dysprosium-iron alloys, targets, NdFeB permanent magnet material containing dysprosium, oxide and compounds
1C906Lutetium itemsMetal, ytterbium-lutetium alloy, targets, oxide and compounds
1C907Scandium itemsMetal, scandium-aluminium, scandium-magnesium and scandium-copper alloys, targets, oxide and compounds
1C908Yttrium itemsMetal, yttrium-aluminium, yttrium-magnesium, yttrium-nickel, yttrium-copper and yttrium-iron alloys, targets including yttrium-aluminium and yttrium-zirconium, oxide and compounds

Software and technology (1D and 1E)

CodeItemControl criteria
1D003Software for superplastic forming toolingSpecially designed or modified for the development, production or use of 1B003 items
1D101Composite production softwareNumerical control software for 1B101.a winding machines and software for 1B101.b tape laying machines
1D201Winding machine softwareSpecially designed for the use of 1B201 equipment
1E003Technology for forming and bonding toolingDevelopment, production or use of 1B003 items, including drawings, process specifications, parameters, programs and simulation data
1E004Technology for tungsten heavy alloysProduction technology and data for 1C004 items
1E101Pyrolytic deposition and tungsten technologyProduction technology for pyrolytic derived materials in the 1300 to 2900 degrees C range, and production technology for 1C117.b, 1C117.c and 1C117.d items
1E103Autoclave and hydraulic vessel technologyData and procedures for controlling temperature, pressure and atmosphere when producing composite parts
1E201Technology for nuclear-related itemsDevelopment, production or use of the 1A202 to 1C241 nuclear-related items and 1D201 software
1E301Technology for pathogens and toxinsDevelopment, production or use of 1C351, 1C353 and 1C354 items
1E302Technology for industrial chemicalsDevelopment, production or use of 1C350 items
1E901Technology for UHMWPEProduction technology and data for 1C901 items, including drawings, process specifications, parameters, programs and simulation data

Sector 2: materials processing

Machine tools, furnaces, presses and measuring systems. This is the sector where a single figure on a datasheet decides the outcome, because the entries are written as accuracy limits measured to ISO 230-2. It is also the sector that produces the most disputes, since a machine sold as a general-purpose lathe can still fall inside 2B201.

Equipment and components (2A)

CodeItemControl criteria
2A225Crucibles for liquid actinide metalsVolume 150 to 8000 cm3 lined with calcium fluoride, calcium zirconate, cerium sulphide, erbium oxide, hafnium oxide, magnesium oxide, niobium-titanium-tungsten, yttrium oxide or zirconium oxide at 2 percent total impurity or less; or tantalum of 99.9 percent purity at 50 to 2000 cm3; or 98 percent tantalum with a tantalum carbide, nitride or boride coating
2A226Bellows-sealed valvesNominal size of 5 mm or more, bellows seal, all wetted surfaces of aluminium, aluminium alloy, nickel or nickel alloy of 60 percent or more
2A901Six-sided press key componentsHinge beams, anvils, and high-pressure control systems operating above 5 GPa

Test, inspection and production equipment (2B)

CodeItemControl criteria
2B005Microwave plasma CVD equipmentMicrowave power above 10 kW at 915 or 2450 MHz, specially designed or manufactured for diamond growth
2B104Isostatic pressesMaximum working pressure of 69 MPa or more, controlled thermal environment of 600 degrees C or more, chamber internal diameter of 254 mm or more
2B105Carbon-carbon densification furnacesChemical vapour deposition furnaces used for densifying carbon-carbon composites
2B117Pyrolytic deposition process controlProcess control equipment for pyrolytic deposition and densification
2B201Machine tools with contouring controlLathes turning diameters above 35 mm with positioning accuracy better than 6 micrometres; milling machines better than 6 micrometres, or with two or more contouring rotary axes, or five or more axes contouring simultaneously; grinding machines better than 4 micrometres, or with two or more contouring rotary axes, or five or more axes; wire electrical discharge machines with two or more contouring rotary axes. Accuracy is measured to ISO 230-2 with all compensations applied
2B204Other isostatic pressesWorking pressure of 69 MPa or more with chamber internal diameter above 152 mm, plus dies, moulds and controllers designed for them
2B206Dimensional inspection systemsCoordinate measuring machines with maximum permissible error of (1.25 + L/1000) micrometres on two axes or (1.7 + L/800) on three or more; linear displacement instruments down to 0.2 micrometres resolution, LVDT linearity of 0.1 percent or better, laser systems with uncertainty of (0.2 + L/2000) micrometres; angular instruments better than 0.00025 degrees; semi-shell line and angle systems
2B207Robots and end effectorsDesigned to national safety standards for handling high explosives, or radiation hardened to withstand more than 5 x 104 Gy without loss of performance, and their specially designed controllers. Automotive paint-line robots are excluded
2B209Flow-forming and spinning machinesThree or more rollers with numerical control or computer control, and mandrels for forming cylindrical rotors of 75 to 400 mm internal diameter
2B210Vibration test systemsElectrodynamic systems with closed-loop control producing 10 g RMS across 20 to 2000 Hz and 50 kN or more of force; digital controllers with real-time bandwidth above 5 kHz; shakers, support structures and ancillary equipment for such systems
2B219Centrifugal balancing machinesFor flexible rotors 600 mm or longer with journal diameter of 75 mm or more, mass capacity 0.9 to 23 kg and rotational speed above 5000 rpm; and machines for hollow cylindrical rotor parts with residual unbalance of 10 g mm/kg or less per plane
2B225Remote manipulatorsFor radiochemical separation or hot cells, able to work through a wall of 0.6 m or more, or over a roof of that thickness
2B226Controlled atmosphere induction furnacesOperating at 850 degrees C or more with induction coil diameter of 600 mm or less and design input power of 5 kW or more, and their power supplies. Semiconductor wafer furnaces are excluded
2B227Vacuum and controlled atmosphere melting furnacesArc remelt, arc melting and arc casting furnaces with consumable electrodes of 1000 to 20000 cm3 above 1700 degrees C; electron beam, plasma atomising and plasma melting furnaces at 50 kW or more above 1200 degrees C; computer control and monitoring systems, plasma torches and electron beam guns designed for them
2B228Rotor and bellows manufacturing equipmentRotor assembly equipment for gas centrifuge tubes, baffles and end caps; rotor straightening equipment; mandrels and dies for single-curvature bellows
2B230Pressure sensorsPressure sensing element and process-wetted housing of aluminium, alumina or sapphire, nickel or nickel alloy of 60 percent or more, or fully fluorinated hydrocarbon polymer, with accuracy better than plus or minus 1 percent of full scale below 13 kPa, or better than plus or minus 130 Pa at the 13 kPa point above it
2B231Vacuum pumpsInlet aperture of 380 mm or more, pumping speed of 15 m3/s or more, ultimate vacuum below 13.3 mPa
2B232High-velocity gun systemsCapable of accelerating projectiles to 1.5 km/s or faster, by propellant, gas, coil, electromagnetic, electrothermal or other advanced means
2B233Bellows-sealed scroll compressors and pumpsInlet volume flow of 50 m3/h or more, compression ratio of 2 to 1 or more, all process-wetted surfaces in aluminium, alumina, stainless steel, nickel, phosphor bronze or fluoropolymer
2B350Chemical production equipmentValves with leak detection ports, bellows-sealed valves and check valves; multi-sealed, canned, magnetic drive, diaphragm and vacuum pumps above 0.6 m3/h or 5 m3/h; storage tanks above 0.1 m3; multi-walled piping; distillation and absorption columns above 0.1 m internal diameter; heat exchangers from 0.15 to 20 m2; reactors from 0.1 to 20 m3; agitators; incinerators above 1000 degrees C for controlled chemicals; remote filling equipment. Control depends on wetted surfaces being glass, fluoropolymer, titanium, zirconium, tantalum, high-nickel alloy, silicon iron, ceramic or graphite. Equipment designed for water treatment, food or pulp and paper is excluded
2B351Toxic gas monitorsDesigned for continuous operation detecting controlled chemicals or organic compounds at phosphorus, sulphur, fluorine or chlorine concentrations below 0.3 mg/m3; and detectors of inhibited cholinesterase activity
2B352Biological handling equipmentBiosafety level 3 and 4 containment facilities; fermenters of 20 litres or more, and smaller units with special combined design; continuous centrifuges above 100 L/h with steam-sterilisable seals; cross-flow filtration from 1 m2 with 0.2 m2 components; freeze dryers from 10 to 1000 kg per 24 hours; positive-pressure suits and class III cabinets; aerosol inhalation chambers of 1 m3 or more; spray and atomisation systems mountable on aircraft or unmanned aircraft; microencapsulation equipment for 1 to 10 micrometre particles; clean rooms and HEPA units for level 3 and 4 facilities
2B901Six-sided cubic pressesBore diameter of 500 mm or more, or design working pressure of 5 GPa or more, with simultaneous pressurisation on all six faces

Materials, software and technology (2C, 2D, 2E)

CodeItemControl criteria
2C901Diamond window materialCurved windows; or planar single-crystal or polycrystalline windows of 3 inches or more with visible light transmission of 65 percent or more
2D101Deposition process softwareSpecially designed for 2B117 items
2D201Equipment use softwareFor the use of 2B204, 2B206, 2B207, 2B209, 2B210.a, 2B210.b, 2B210.d, 2B210.e, 2B219 and 2B227 equipment
2D202Machine tool softwareDevelopment, production or use of 2B201 equipment. Part-programming software that only produces numerical control code is excluded
2D203Numerical control unit softwareSoftware that lets an electronic unit control five or more interpolating axes contouring simultaneously, whether exported separately or installed
2E201Technology for processing equipmentDevelopment, production or use of the 2A225, 2A226, 2B201, 2B204, 2B206 to 2B233 items and 2D201 to 2D203 software
2E301Technology for biological equipmentDevelopment, production or use of 2B352 items
2E302Technology for chemical equipmentDevelopment, production or use of 2B350 and 2B351 items
2E901Technology for cubic pressesProduction technology for six-sided cubic presses, and process technology for synthesising diamond or cubic boron nitride single crystals in them

Sector 3: electronics

Two groups sit here. One is the missile-electronics legacy list of converters, capacitors, switches, detonators and mass spectrometers. The other is the metals family added in December 2024 and now the most commercially sensitive part of the whole list: gallium, germanium, antimony and indium, including their oxides, epitaxial wafers and organometallics.

CodeItemControl criteria
3A101Analogue-to-digital convertersOperating from minus 54 to 125 degrees C, or built to military ruggedised specifications, or radiation hardened, with conversion rates above 200000 complete conversions per second, accuracy better than 1/10000 of full scale, or a figure of merit above 1 x 108
3A201Capacitors, electromagnets and acceleratorsPulse discharge capacitors above 1.4 kV with more than 10 J, or above 750 V with more than 0.25 microfarad and series inductance below 10 nH; superconducting solenoidal electromagnets above 2 T with length to bore ratio above 2 and bore above 300 mm; flash X-ray generators and pulsed electron accelerators in the 0.5 to 25 MeV band with a figure of merit of 0.25 or more, or above 25 MeV at 50 MW. Medical accelerators and MRI magnets are excluded
3A225Frequency convertersPolyphase output of 40 VA or more, operating at 600 Hz or above, with frequency control better than 0.2 percent. Covers inverters, variable speed drives and variable frequency drives, including units built into machinery where they can be removed and used elsewhere
3A226High power direct current supplies100 V or more at 500 A or more continuously for 8 hours, with current or voltage stability better than 0.1 percent
3A227High voltage direct current supplies20 kV or more at 1 A or more continuously for 8 hours, with stability better than 0.1 percent
3A228Switching devicesCold-cathode tubes with three or more electrodes rated at 2.5 kV peak and 100 A peak with anode delay of 10 microseconds or less; triggered spark gaps with delay of 15 microseconds or less and 500 A peak; fast switching modules above 2 kV and 500 A with turn-on time of 1 microsecond or less
3A229Firing sets and pulsed power generatorsFiring sets for multiple detonators, including electrically, explosively and optically driven types; modular electric pulse generators that are portable or ruggedised, deliver energy into a load below 40 ohm within 15 microseconds at above 100 A, fit within 30 cm, weigh under 30 kg and work from minus 50 to 100 degrees C; micro firing sets under 35 mm at 1 kV or more with 100 nF or more
3A230High-speed pulse generatorsOutput above 6 V into a load below 55 ohm with pulse transition time below 500 picoseconds, including pulse heads
3A231Neutron generator systemsDesigned to work without an external vacuum system, using electrostatic acceleration for tritium-deuterium reactions, or deuterium-deuterium reactions producing 3 x 109 neutrons or more
3A232Detonators and multipoint initiationExploding bridge, exploding bridgewire, slapper and exploding foil initiators; and systems that initiate an explosive surface above 5000 mm2 from a single signal within 2.5 microseconds. Detonators using only primary explosives such as lead azide are excluded
3A233Mass spectrometersCapable of measuring ions of 230 atomic mass units or more with resolution better than 2/230: inductively coupled plasma, glow discharge, thermal ionisation, electron bombardment with molecular beam inlet and cold trap, and instruments with micro-fluorination ion sources for actinides
3A234Strip lines for detonatorsRated above 2 kV with inductance below 20 nH
3C001Gallium itemsGallium metal; gallium nitride, gallium oxide, gallium phosphide, gallium arsenide, indium gallium arsenide, gallium selenide and gallium antimonide, in polycrystalline, single crystal, wafer, epiwafer, powder or scrap form
3C002Germanium itemsGermanium metal in crystal, powder or scrap form; zone-refined ingots; zinc germanium phosphide; germanium epitaxial substrates; germanium dioxide; germanium tetrachloride
3C003Antimony itemsAntimony ore and raw material; antimony metal and articles in ingot, block, bead, granule or powder form; antimony oxide of 99.99 percent purity or more; trimethyl and triethyl antimony and other organoantimony compounds above 99.999 percent; antimony hydrides above 99.999 percent; indium antimonide single crystal with dislocation density below 50 per cm2 or polycrystal above 99.99999 percent
3C004Indium itemsIndium phosphide, trimethyl indium and triethyl indium
3D224Frequency converter software and keysSoftware or encryption keys designed to raise equipment to the 3A225 performance level
3D225Frequency converter softwareSpecially designed for the performance characteristics of 3A225 items
3E003Gold-antimony smelting technologySeparation technology for gold and antimony
3E004Indium production technologyTechnology and data for producing 3C004 items
3E201Technology for electronic and accelerator itemsDevelopment, production or use of the 3A201 to 3A234 items and associated software

Sectors 4 and 5: computers, telecoms and information security

Small sectors, but they catch ordinary commercial hardware more often than people expect, because encryption sits inside almost every router, laptop and payment terminal.

Sector 4: computers
CodeItemControl criteria
4A003High-performance digital computersAdjusted peak performance above 8.0 weighted teraflops; electronic assemblies designed to raise aggregate performance above that level; external interconnect equipment above 2.0 Gbyte/s single-link unidirectional rate. Internal backplanes, passive interconnect, network access controllers and channel controllers are outside
4A101Ruggedised computersAnalogue or digital machines operating continuously from minus 45 to 55 degrees C, or hardened and radiation hardened
4A102Hybrid computers for missile workSpecially designed for modelling, simulation or overall design of missiles and rocket systems
4D102Missile design softwareSpecially designed for modelling, simulation or design of missiles and rocket systems
Sector 5: telecommunications and information security
CodeItemControl criteria
5A002Information security systems and componentsSecurity chips performing encryption, key management or random number generation with symmetric keys above 64 bits, factorisation-based asymmetric keys above 768 bits or elliptic curve keys above 128 bits; crypto machines and cards at 10 Gbps or 50000 signatures per second; IPsec and SSL VPN appliances at 10 Gbps; key management servers handling more than 10000 objects; dedicated crypto devices for power, tax, police and finance; quantum cryptography equipment. This is the entry that catches commercial network gear
5A004Cryptanalysis equipmentDesigned to break, weaken or bypass cryptographic technology, products or systems
5A101Telemetry equipmentTelemetry systems, and ground equipment for telemetry or remote control
5B002Crypto test and production equipmentEquipment designed to develop or produce 5A002 and 5A004 items, and equipment designed to measure, test, evaluate or validate them
5D002Crypto softwareSpecially designed or modified for 5A002, 5A004 or 5B002
5E002Crypto technologySpecially designed or modified for 5A002, 5A004, 5B002 or 5D002
5E101Telemetry technologyDevelopment, production or use of 5A101 items

Sector 6: sensors and lasers

CodeItemControl criteria
6A102Re-entry vehicle protection componentsRadiation hardened microcircuits and detectors, and hardened structures that survive combined thermal shock of 418 J/cm2 and overpressure of 50 kPa
6A108Target detection electronicsRadar, terrain contour mapping, scene mapping, imaging sensors, and electronics that exclude conducted heat, resist radiation, work briefly above 125 degrees C or carry a specially designed structural support. Equipment integrated into civil aircraft is excluded
6A202PhotomultipliersPhotocathode area above 20 cm2 with anode pulse rise time below 1 nanosecond
6A203High-speed cameras and imagingStreak cameras recording faster than 0.5 mm per microsecond or resolving below 50 nanoseconds; framing cameras above 225000 frames per second or with exposure of 50 nanoseconds or less; solid state and tube cameras with gating of 50 nanoseconds or less; electro-optic shutters; radiation-hardened television cameras above 5 x 104 Gy
6A205Lasers, amplifiers and oscillatorsCopper vapour lasers from 30 W at 500 to 600 nm; argon ion lasers from 40 W at 400 to 515 nm; neodymium lasers at 1000 to 1100 nm above 40 W single transverse mode or 50 W multimode; tunable pulsed dye oscillators and amplifiers; alexandrite lasers above 30 W; pulsed carbon dioxide lasers above 500 W with pulses under 200 nanoseconds; excimer lasers above 500 W; para-hydrogen Raman shifters at 16 micrometres; pulsed carbon monoxide lasers above 200 W. Continuous-wave industrial cutters and welders are excluded
6A225Velocity interferometersMeasuring velocities above 1 km/s within intervals below 10 microseconds, including VISAR, Doppler laser interferometer and photonic Doppler velocimeter types
6A226Pressure sensors for shock workShock pressure gauges measuring above 10 GPa, including manganin, ytterbium and PVDF gauges; quartz pressure transducers above 10 GPa
6C001Bismuth itemsBismuth metal and articles outside 1C229, including ingots, blocks, beads, granules and powder; bismuth germanate; triphenyl bismuth; tris(ethoxyphenyl) bismuth
6C002Tellurium itemsTellurium metal; single-crystal or polycrystalline articles of cadmium telluride, cadmium zinc telluride and cadmium mercury telluride, including substrates and epiwafers
6D203Camera performance softwareDesigned to bring 6A203.a, 6A203.b or 6A203.c equipment up to or beyond the controlled performance level
6D204Camera software and keysSpecially designed software or encryption keys for the performance of 6A203 items
6E001Bismuth production technologyTechnology and data for producing 6C001 items
6E002Tellurium production technologyTechnology and data for producing 6C002 items
6E201Technology for sensor and laser itemsDevelopment, production or use of the 6A202 to 6A226 items and associated software

Sector 7: navigation and avionics

Almost every entry ends with the same carve-out: equipment integrated into civil aircraft and general aviation is not controlled, and unmanned aircraft are governed by sector 9 instead.

CodeItemControl criteria
7A101AccelerometersScale error below 0.25 percent
7A102GyroscopesRated drift rate below 0.5 degrees per hour
7A103Guidance and control equipmentGyro-stabilised platforms, and autopilots specially designed for unmanned aircraft
7A104Astronomical gyrocompassesAnd other devices navigating by celestial bodies or satellites
7A105Navigation data processorsSpecially designed for navigation
7A106AltimetersDesigned for target detection
7B101Accelerometer test equipmentAccelerometer test benches and axis alignment benches
7B102Gyro and inertial test equipmentGyro tuning and dynamic balance testers, run-in stands, evacuation and filling stands, centrifuge fixtures, ring laser gyro scatterometers and reflectometers, surface profilometers, inertial platform test benches, IMU testers and balancing fixtures
7B103Calibration equipmentTest, calibration and alignment devices specially designed for gyroscopes or accelerometers
7D101Flight control softwareFlight control and test software. Software integrated into civil aircraft is excluded
7D105Navigation processor softwareSpecially designed for 7A105 items
7E102Electromagnetic protection design technologyShielding system design, hardened circuit and subsystem layout, and the standards used to verify them

Sector 8: marine

One entry, and it is the one that catches construction equipment rather than ships.

CodeItemControl criteria
8A901DredgersTrailing suction hopper dredgers with hopper capacity of 1500 m3 or more, dredging depth of 15 m or more, or bow discharge equipment; cutter suction dredgers with cutter power of 500 kW or more, depth of 15 m or more, or installed power of 2000 kW or more; bucket dredgers with bucket capacity of 4 m3 or more or depth of 15 m or more; sand suction vessels with hopper capacity of 500 m3 or more or installed power of 1000 kW or more; self-propelled split hopper barges with capacity of 1000 m3 or more or bow discharge and self-unloading gear

Sector 9: aerospace and propulsion

The unmanned aircraft entries have been rewritten twice in two years, and the current thresholds are the ones set out below, with a further revision taking effect on 18 November 2026 detailed in the amendments section.

CodeItemControl criteria
9A012Unmanned aircraft and airshipsControllable flight beyond the operator's natural line of sight with endurance of 30 minutes or more and take-off and stable flight in 25 knot gusts, or endurance of one hour or more; reciprocating or rotary engines for flight above 15420 m, or aero engines above 16 kW; payloads including infrared imagers at 780 to 30000 nm with instantaneous field of view below 2.5 mrad, synthetic aperture radar beyond 5 km at 0.3 m strip mode or 0.1 m spot mode resolution, target designation lasers above 80 mJ, inertial measurement units with heading accuracy below 2 degrees; conversion equipment for manned aircraft; radio links beyond 50 km or controlling more than 10 aircraft from one station. Model aircraft are excluded
9A101Turbojet and turbofan enginesTurbojets of 90 kN thrust or more, turbofans, and combined cycle engines, other than those in 9A012.b. Engines integrated into civil aircraft are excluded
9A106Propellant control systemsLiquid and slurry propellant control systems working from 20 to 2000 Hz at 10 g RMS: servo valves above 7000 kPa absolute at 24 L per minute with actuator response under 100 microseconds, and pumps above 8000 rpm delivering 7000 kPa or more
9A111Air-breathing propulsionRamjet, scramjet, pulsejet and combined cycle engines and their combustion regulators
9A501Other unmanned aircraftRange of 300 km or more; or autonomous flight control and navigation with an aerosol dispersal system above 20 litres; or beyond line of sight control with the same dispersal capability. Model aircraft for recreation or competition are excluded
9B001Turbine manufacturing equipmentDirectional solidification or single crystal casting equipment for superalloy turbine blades and vanes, and precision casting consumables such as ceramic cores, wax patterns and shells, with the tooling and fixtures for them
9B004Turbine disc bonding toolingTooling, moulds and fixtures for solid state bonding of superalloy, titanium and intermetallic discs
9B105Wind tunnelsSupersonic from Mach 1.4 to 5 and hypersonic from Mach 5 to 15. Teaching tunnels under 25 cm internal dimension are excluded
9B116Engine production facilitiesProduction facilities specially designed for 9A101, 9A106 and 9A111 items
9B117Rocket test standsStands able to test solid or liquid propellant rocket engines above 90 kN thrust, or able to measure three thrust components simultaneously
9C110Structural compositesResin or metal matrix composites reinforced with fibre or filament where specific tensile strength exceeds 7.62 x 104 m and specific modulus exceeds 3.18 x 106 m: polyimide, polyamide, polycarbonate, quartz, carbon, boron, magnesium and titanium matrix composites
9C116Ceramic and ablative heat protectionCeramic thermal protection materials and ablative materials
9D001Software for turbine equipmentDevelopment, production or use of 9B001 and 9B004 items
9E001Technology for turbine equipmentDevelopment, production or use of 9B001 and 9B004 items, including drawings, specifications, parameters, programs and simulation data
9E101Re-entry vehicle technologyDesign and manufacture of ceramic and ablative heat parts, heat sinks, radiation hardening and hardened structures

Sector 0: other items

CodeItemControl criteria
0A901High-pressure water cannonMaximum range of 100 m or more, rated flow of 540 m3/h or more, rated pressure of 1.2 MPa or more
0A902Water cannon componentsMain components and ancillary equipment specially designed for 0A901 items: cannon body, high-pressure pump and control system
0A903Civil counter-drone systemsElectronic jamming equipment with a range beyond 5 km; high-power lasers above 1.5 kW output specially designed for counter-drone use
0B901Spacesuit visor toolingMoulds specially designed for manufacturing spacesuit visors
0D901Software for visor toolingDevelopment, production or use of 0B901 items
0E901Technology for visor toolingDevelopment, production or use of 0B901 items, including drawings, specifications, parameters, programs and simulation data

Every amendment since 2024

The consolidated list is a living document. Six packages have changed the list since publication, and one of them is suspended rather than withdrawn, which means it comes back unless something replaces it. Each notice is listed with its ministry page at the end of this guide.

Amendments to the control list
DateInstrumentWhat it doesStatus and effective date
15 Nov 2024Notice 51 of 2024Publishes the consolidated list: 189 codes in ten sectors, replacing the nuclear, missile, biological, chemical and cryptography lists and a dozen announcementsIn force from 1 Dec 2024
4 Apr 2025Notice 18 of 2025Adds seven rare earth elements as 1C902 to 1C908: samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium, covering metal, alloys, targets, NdFeB magnet material containing terbium or dysprosium, oxides and compoundsIn force from 4 Apr 2025
9 Oct 2025Notices 55, 56, 57, 58, 61 and 62 of 2025Superhard materials; rare earth equipment and raw materials; further medium and heavy rare earths; lithium-ion batteries and artificial graphite anode material; rare earth items produced abroad; rare earth technologySuspended from 7 Nov 2025 to 10 Nov 2026. They return on 11 Nov 2026 unless the suspension is extended
5 Aug 2026Notice 34 of 2026Tightens drone-related dual-use controls for exports to the United StatesIn force
19 Oct 2026Notice 49 of 2026Rewrites the unmanned aircraft entries, adds nine new codes and a registration channel for lower-risk exportsEffective 18 Nov 2026
19 Oct 2026Notice 50 of 2026Controls tunnel boring machines, walking excavators and high-altitude wet shotcrete machines with their components and technologyEffective 18 Nov 2026
19 Oct 2026Notice 51 of 2026Adds dredger pumps, drag heads and cutter heads under 8A901, replacing the earlier broad dredger wordingEffective 18 Nov 2026
19 Oct 2026Notice 52 of 2026Procedural only: the customs query notice, the seven-day evidence window and the assessment deadlinesIn force from publication
The suspended package matters commercially. Lithium-ion cells above 300 Wh/kg, artificial graphite anode material, diamond micro powder, wire saws and a further group of medium and heavy rare earths were published on 9 October 2025, were suspended the day before they were due to take effect on 8 November, and return on 11 November 2026 unless the suspension is extended. A booking that straddles that date needs a view on which way it goes, because the announcement set an end date rather than a repeal.

Added on 18 November 2026: unmanned aircraft

Notice 49 replaces the unmanned aircraft entries rather than adding to them. Endurance bands widen, the dispersal threshold rises from 20 to 80 litres, and the component level is reached for the first time, which is what pulls motor, ESC and propeller suppliers into scope.

CodeItemControl criteria
9A012.aUnmanned aircraft and airshipsControllable beyond the operator's natural line of sight with endurance of 30 minutes to 3 hours plus take-off and stable flight in 25 knot gusts, or endurance of 3 hours or more
9A012.bEngines for unmanned aircraftReciprocating or rotary engines for flight above 15420 m; aero engines above 16 kW continuous; turbojets of 400 N thrust or more
9A012.eRadio links for unmanned aircraftAirborne equipment with equivalent isotropic radiated power of 30 dBm or more, or one station controlling more than 10 aircraft
9A112Other unmanned aircraftRange of 300 km or more; autonomous flight control and navigation with aerosol dispersal above 80 litres; beyond line of sight control with the same dispersal capacity. Model aircraft for recreation or competition excluded
9A901Unmanned aircraft componentsBrushless motors at 48 V or more, 3 kW or more, power density of 3 kW/kg or more and speed of 3000 rpm or less; matching electronic speed controllers; carbon fibre composite blades from 762 mm tip radius, or 648 mm root-to-tip, or with variable pitch at the root
7A103.bAutopilots for unmanned aircraftSpecially designed autopilots, HS reference 90142010.10
7E103Autopilot technologyGimbal stabilisation technology for 7A103.a, mission payload technology for 7A103.b
9D901Software for unmanned aircraftSpecially designed for 9A012.a and 9A112 items
9E901Unmanned aircraft technologyFlight control including swarm control, autonomous navigation including inertial, terrain matching and anti-jamming satellite navigation, sense and avoid, and whole-aircraft system design
9E902Engine and component technologyFor 9A012.b, 9A012.c, 9A012.d, 9A012.e and 9A901 items
9E903Polar light unmanned aircraft technologyShip or ice operation, take-off in force 6 wind, working to minus 30 degrees C, endurance of 6 hours or more and payload of 10 kg or more
9E904Mixed human-machine control technologyFor ground unmanned platforms in weak communication environments, with defined compression, latency and success-rate thresholds
0E903Counter-drone technologyDevelopment, production or use of 0A903 items

Added on 18 November 2026: construction and tunnelling equipment

These three families are new to the list and matter to anyone shipping capital equipment out of China, including project cargo and breakbulk.

CodeItemControl criteria and HS reference
2B906Full-face tunnel boring machinesEarth pressure balance, slurry shield and other shields, plus open, single shield and double shield rock TBMs. HS 8430313010
2A906TBM componentsCutter heads, screw conveyors, segment erectors, main drive systems and other key units designed for 2B906. HS 8431499910, 8428310010, 8479899959
2E906TBM remanufacturing technologyTechnology for remanufacturing 2A906 and 2B906 items
2B904Walking excavatorsClearing vertical obstacles above 1.2 m, wading deeper than 1.5 m, crossing trenches wider than 3 m, or climbing gradients above 40 degrees. HS 8429521920
2E904Walking excavator technologyElectro-hydraulic proportional control technology for the hydraulic system of 2B904 items
2B903High-altitude wet shotcrete machinesFor use above 3000 m, with engine above 75 kW and 680 Nm, motor above 55 kW, pumping intake efficiency above 95 percent, compressor above 15 m3/min and low-temperature hydraulic oil rated to minus 20 degrees C. HS 8479109010
2A903Shotcrete machine componentsHigh-altitude engines, auxiliary oxygen supply, motors, two-stage compressors, chassis and folding booms designed for 2B903 items
2E903Shotcrete technologyHydraulic and pumping technology for 2B903 items
Notice 50 carries an unusual licensing structure. Exports to sensitive countries and regions in dispute with China need a licence; exports elsewhere obtain an export certificate by registering the information, on an undertaking that the goods will not be transferred onward to those countries without a licence.

Added on 18 November 2026: dredger components

Notice 51 narrows and sharpens 8A901. The dredger itself remains controlled on the thresholds set out above; the change is that pumps, drag heads and cutter heads are now named as controlled items in their own right, with HS references.

CodeItemControl criteria and HS reference
8A901.f.1.aDredger pumpsSuction inlet diameter of 0.55 m or more with maximum pump speed of 400 rpm or less. HS 8413709120, 8413709980
8A901.f.1.bPump casings and impellersCasing bore of 1.3 m or more, including inner and outer casings; impeller diameter of 1.3 m or more. HS 8413910010
8A901.f.2Drag headsFor trailing suction hopper dredgers, with suction pipe diameter of 0.55 m or more. HS 8479109010
8A901.f.3Cutter headsFor cutter suction dredgers, with cutter ring outer diameter of 2.1 m or more. HS 8479109010

The items that stop cargo most often

Reading 189 codes is not what a shipper does before every booking. In practice the same eight families produce nearly every query at the port.

Where to look first
GoodsCodes to checkWhat usually decides it
Rare earth metals, oxides, alloys and magnets1C902 to 1C908Whether the material is a controlled element, and whether an NdFeB magnet contains terbium or dysprosium at all. Magnet grade and composition matter more than the product name
Graphite1C108Density, purity, flexural strength and whether the material is natural flake, spheroidised or expanded graphite. Battery anode material is caught here
Gallium, germanium, antimony, indium3C001 to 3C004Form and purity: metal, oxide, wafer, epiwafer, powder or scrap all count, and purity thresholds are explicit
Unmanned aircraft and parts9A012, 9A501, 9A112, 9A901Endurance, range, dispersal tank size, radio link power, and from November 2026 the motor and propeller specification
Machine tools2B201, 2B204, 2B206Positioning accuracy to ISO 230-2 and the number of contouring axes. The datasheet figure decides; a general-purpose description does not
Lithium cells and batteries3A001 (suspended package), 1C108Energy density above 300 Wh/kg under the suspended lithium entry; graphite anode material under 1C108. Both depend on the status of the October 2025 package
Ballistic and protective material1C901, 1C210Fibre strength and modulus, and whether UD laminate meets the V50 threshold. Body armour fabric is not exempt because it is textile
Encryption and network hardware5A002, 5D002, 5E002Key length and throughput. Ordinary commercial routers and VPN appliances with strong encryption fall inside

What the shipper has to do

The obligations below apply to every entry, licence or no licence, and all of them are checked against the declaration rather than against the product.

None of this replaces the catch-all. Article 12 of the Export Control Law requires a licence for unlisted goods where the exporter knows, should know or has been notified that they may endanger national security, serve weapons of mass destruction or their delivery systems, or support terrorism. An HS code absent from the list settles nothing on its own.

Frequently Asked Questions

How many items are on the Chinese dual-use list?

The consolidated text carries 189 control codes across ten industry sectors, counted as top-level five-character codes with their lettered and numbered sub-items underneath. The June 2026 printed version runs to 147 pages. Notice 49, 50 and 51 of 2026 add further codes for unmanned aircraft components, tunnel boring machines, walking excavators, shotcrete machines and dredger parts, effective 18 November 2026, so the number moves with each amendment package.

My product has an HS code that appears in the list. Is it controlled?

No. The list controls on technical parameters, and the HS references in the announcements are references for declaration convenience, not a definition of scope. A hammer drill and a tunnel boring machine can share a heading; only one is controlled. The reverse is also true: goods off the list can still require a licence under the catch-all in Article 12 of the Export Control Law.

Are the October 2025 rare earth, lithium battery and superhard material controls in force?

No. Notices 55, 56, 57, 58, 61 and 62 of 2025 were suspended from 7 November 2025 until 10 November 2026. They were not repealed, so on 11 November 2026 they return unless the suspension is extended or the measures are replaced. Any classification for lithium cells above 300 Wh/kg, artificial graphite anode material, diamond micro powder or the fifth group of rare earths should be re-checked before that date.

Do software and technology need a licence, or only physical goods?

They need a licence. Every sector carries D and E codes for software and technology, and the definition of technology includes drawings, process specifications, process parameters, machining programs and simulation data. Sending a process recipe by email, or uploading a machining program to a customer's machine, is an export of technology.

Is a five-axis machining centre automatically controlled?

For a milling machine, yes. Two or more contouring rotary axes, or five or more axes contouring simultaneously, brings the machine inside 2B201 whatever its accuracy, so a five-axis mill is controlled by definition of its axes. A three-axis machine is judged on positioning accuracy to ISO 230-2, where the threshold is 6 micrometres for milling and 4 micrometres for grinding. Lathes are judged on accuracy alone, at 6 micrometres for work above 35 mm diameter.

Are small drones and hobby models caught?

Models designed for recreation or competition are expressly excluded from 9A012 and 9A501, and the same exclusion appears in the November 2026 text. Beyond that, size is not the test: endurance beyond 30 minutes, range of 300 km, autonomous flight with a large dispersal tank, or a radio link above 50 km are the thresholds, and from 18 November 2026 certain motors, speed controllers and carbon propellers are controlled as components regardless of the aircraft they are intended for.

Where is the authoritative current text?

The Ministry of Commerce publishes the consolidated list as a PDF through the China Export Control Information portal, and each amending notice states that the list is updated in step. Because the consolidated PDF lags the newest notices by some weeks, the working answer is to read the list for the item and the notices for the date. Our guide to the customs query procedure covers what happens when the two readings disagree at the port.

Sources

Every code, threshold and date here is taken from the documents below. All ten are published by the Ministry of Commerce, and all ten are in Chinese. Where a figure here disagrees with a broker's summary or a blog post, the ministry page is the one that counts.

The primary documents behind this guide
DocumentPublishedTitle as issued, rendered in EnglishSource page
Notice 51 of 202415 Nov 2024Announcement of the Consolidated List of Dual-Use Items Subject to Export Control, issued with the Ministry of Industry and Information Technology, the General Administration of Customs and the State Cryptography Administration. The landing page for the list itself, and the only place the current edition is publishedexportcontrol.mofcom.gov.cn
Consolidated list,
June 2026 edition
12 Jun 2026The list as a PDF: 147 pages, 189 top-level control codes across ten sectors. The code-by-code sections above were read from this filePDF, 147 pages
Notice 18 of 20254 Apr 2025Decision to impose export control on certain medium and heavy rare earth items: samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium, added as 1C902 to 1C908mofcom.gov.cn
Notice 56 of 20259 Oct 2025Decision on certain rare earth equipment and raw materials. One of the six notices issued on 9 October 2025, cited here as the representative text; Notices 55, 57, 58, 61 and 62 sit beside it on the same sitemofcom.gov.cn
Notice 70 of 20257 Nov 2025Decision to suspend Notices 55, 56, 57, 58, 61 and 62 of 2025 from the date of publication until 10 November 2026. The warning above about 11 November 2026 rests on this documentmofcom.gov.cn
Notice 34 of 20265 Aug 2026Strengthening export control on unmanned aircraft-related dual-use items for the United States: case-by-case review with no licence facilitationmofcom.gov.cn
Notice 49 of 202619 Oct 2026Optimising and adjusting export control measures on unmanned aircraft-related items, issued with the Central Military Commission Equipment Development Department: nine new codes, a raised dispersal threshold and a registration channel, effective 18 November 2026mofcom.gov.cn
Notice 50 of 202619 Oct 2026Decision to impose export control on tunnel boring machines and other items: 2B906, 2A906 and 2E906 together with walking excavators and high-altitude wet shotcrete machines, effective 18 November 2026mofcom.gov.cn
Notice 51 of 202619 Oct 2026Optimising and adjusting export control measures on dredger-related items: 8A901.f pumps, drag heads and cutter heads, replacing the earlier broad wording, effective 18 November 2026mofcom.gov.cn
Notice 52 of 202619 Oct 2026Further improving the customs query and identification procedure for dual-use items: the seven-day evidence window and the assessment deadlines a shipment either meets or missesmofcom.gov.cn

Where to check a licence question

Two cautions about using these pages. The consolidated PDF is regenerated in place whenever the list is amended, so the file address changes and a bookmark to the PDF will rot; bookmark the Notice 51 of 2024 page instead, since it always carries the current edition. And the list is never the whole obligation, because Article 12 of the Export Control Law reaches items that appear nowhere in it.

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