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Dual-Use Items the Application Process

How Factories or Exporters Can Formally Export Dual-Use Items and the Application Website & Process

How to formally import dual-use items or products containing rare metals from China, what suppliers need to do to export legally and compliantly, the application process, which department to apply to, how to apply, the website, etc.

An increasing number of products, especially export goods related to rare earths, are being included in China's export control list. Before 2024, there were no specific requirements for exporting many products involving rare metals. Now, in 2025, Chinese factories or exporters are unsure how to declare these products correctly when encountered.

In the past, when they partnered with international freight forwarders in China to handle the export of these products by sea or air, the forwarders often failed to pay attention to the specific characteristics of these products and to stay abreast of changes in Chinese customs export requirements. This led to customs inspections, returns, and fines. Other issues included misdeclaring product names in export declarations, concealing information, and exporting through Hong Kong, all of which resulted in financial losses for the shipping companies and their customers.

Alternatively, irregular methods such as misdeclaring product names, concealing declarations, or shipping exports via Hong Kong were used.

These practices have caused economic and customer losses for the shipping companies.

How to formally import "dual-use items" and products containing newly controlled rare metals from China? The key is for the Chinese supplier or exporter to obtain an Export License in advance from the Ministry of Commerce of the People's Republic of China (MOFCOM).

What procedures are required for exporting rare metals and products containing rare metals? How to export rare metals and products containing rare metals legally and compliantly? The following process is the correct application procedure.

Process for Chinese Export Companies to Apply for Dual-Use Items

Export operators shall strictly comply with relevant national export control laws, regulations, and rules. They must truthfully complete all sections of the Dual-Use Items Export License Application Form within the MOFCOM Unified Platform and submit authentic and valid application materials as required. All electronic scans and copies of materials must be completely consistent with the originals.

MOFCOM Unified Platform: (https://ecomp.mofcom.gov.cn)

Before formally submitting the application, applicants should self-check the dual-use items export license application materials, focusing on three aspects: completeness, standardization, and consistency.

  • I. Completeness of Application Materials

    The following materials should be submitted for the export license:

    1. 1. Application form.
    2. 2. Copy of the contract, agreement, or other supporting documents.
    3. 3. Technical description or test report of the item intended for export.
    4. 4. End-User and End-Use Certificate (including Chinese translation).
    5. 5. Introduction to the importer and end-user (including Chinese translation).
    6. 6. Identity documents of the applicant's legal representative, key management personnel, and handling personnel.
    7. 7. Other documents required by MOFCOM (applicants may proactively submit other materials helpful for the review).
  • II. Standardization of Application Materials

    1. 1. Application Form: Fill out all sections accurately and standardly. The section for the legal representative's signature must be personally signed by the legal representative or their authorized person (a power of attorney must be submitted) and stamped with the company's official seal. The application form must have the company's chop (seal) applied across the gutter between the two(couplets/parts).
    2. 2. Contract/Agreement: Must contain complete contract/agreement number, signing date, product name, exporter, importer, and other information. The exporter should be an enterprise within China (including special customs supervision areas and bonded premises), and the importer should be a foreign enterprise or an enterprise from the Hong Kong, Macao, or Taiwan regions of China. The contract or agreement should be signed by both parties or stamped with their company seals. It is recommended to include export control compliance clauses in the contract.
    3. 3. Technical Description or Test Report of the Item: Compare with the descriptions of specific items in the Control List and announcements. Clearly provide the actual parameters of the export item to ensure a clear judgment can be made that the intended export commodity falls within the controlled scope.
    4. 4. End-User and End-Use Certificate: Should generally be issued according to a template, with complete user information and commitment points. The original English version requires the signature and seal of the foreign party's responsible person. If the foreign party does not have an official seal, the relevant situation must be explained. The Chinese translation should be stamped with the exporter's seal to confirm translation accuracy. If the end-user is an enterprise from the Hong Kong, Macao, or Taiwan regions, it should be issued using the specific template for those regions.
    5. 5. Importer and End-User Introduction: Content includes but is not limited to the enterprise's legal person, establishment date, business scope, asset size, number of employees, company website, main products, etc. It can also provide actual production scenarios, product photos, past cooperation history, etc.
    6. 6. Identity Documents: Include identity documents and clear copies of the ID documents for the legal representative, key responsible persons, and handling personnel involved in the application process. Relevant materials and documents should be valid.
    7. 7. Other Materials: May include unit of measurement conversion explanations, historical export records and actual usage of the items, explanation for the reasonableness of the export quantity, etc. If returned by the competent authority, modify or supplement the relevant materials according to the system's return requirements before resubmitting.
  • III. Consistency of Application Content

    1. The application form number on the uploaded materials must match the system application form number.
  • 2. Information such as contract number, contract signing date, consignee, importer, end-user, product specifications and model, quantity, unit, price, etc., on the application form must be consistent with the content of the uploaded contract. If inconsistencies exist, an explanatory note stating the reason should be attached, e.g., unit of measurement conversion explanation.
  • 3. Information such as contract number, product name, exporter name, end-user name and address, and end-use description on the application form must be consistent with the corresponding information in the End-User and End-Use Certificate.
  • 4. Information regarding the legal representative and other relevant personnel on the application form must be consistent with the uploaded identity documents.
  • 5. Information such as importer and end-user filled in the application system should be consistent with the corresponding information in the contract, importer and end-user introduction, End-User and End-Use Certificate, and other materials.
  • 6. The export item listed on the application form must be consistent with the item described in the uploaded technical documentation.

Website for Applying for Dual-Use Items Export License

Ministry of Commerce of the People's Republic of Republic Unified Platform: (https://ecomp.mofcom.gov.cn)

After application, Chinese export enterprises will receive a "Dual-Use Items Export License" from the Ministry of Commerce of the People's Republic of China.

During export customs declaration, the enterprise submits this license to the customs system along with other declaration documents to proceed with normal export customs declaration.

Of course, such products often belong to liquid, powder, paste chemical products, or dangerous goods. Therefore, for sea or air transportation, a "Certification for Safe Transport of Chemical Goods for sea" or an "Certification for Safe Transport of Chemical Goods for air" (Transportation Identification Report for Dangerous Goods) must also be prepared.

In this way, products involving Chinese export controls can be exported formally, legally, and smoothly.

How to import rare metal products from China legally and in compliance with regulations

The latest news on China's regulations on the export of rare metals

On February 4, 2025, the Ministry of Commerce and the General Administration of Customs announced the decision to implement export controls on items related to tungsten, tellurium, bismuth, molybdenum, and indium, and on 25 types of rare metal products and their technologies, such as ammonium paratungstate.

Medium and Heavy Rare Earths: On April 4, 2025, the Ministry of Commerce and the General Administration of Customs jointly announced export controls on items related to seven types of medium and heavy rare earths: samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium. This includes various forms such as metals, alloys, targets, permanent magnet materials, oxides, compounds, and their mixtures.

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