China Announces Customs Inquiry Procedures for Export Control of Dual-Use Items

On June 16, 2025, the China General Administration of Customs (GACC) released Notice No. 123 of 2025, titled “Announcement on Matters Related to Customs Inquiries on Export Control of Dual-use Items.” This notice introduces inquiry procedures for the export control of dual-use items, with the goal of enhancing efficiency and transparency of customs inquiries involving potentially controlled goods. The policy is based on the following legal frameworks:

Customs Inquiry Notification

Customs will initiate a formal inquiry under the following circumstances:

Consignor of export goods fails to provide a valid license issued by the national export control authority, and
Customs has reason to believe that the export goods may fall within the scope of export control.

In such cases, customs shall issue the Customs Inquiry Notice on Export Control of Dual-Use Items (Annex 1) to the consignor.

Submission of Supporting Materials

Upon receipt of the Customs Inquiry Notice, the consignor shall submit the following materials within 7 working days, bearing the official company seal and responsibility for their authenticity. If any of the submitted materials are in foreign language, a Chinese translation shall also be provided.

1. Printed customs declaration form

2. Export goods contract

3. Written explanation outlining the nature of the goods, including performance specifications, primary applications, and justification as to why the goods are not subject to export control regulations

4. Relevant technical documentation, including inspection and testing reports

5. Any additional materials required by customs per regulatory needs.

Processing and Outcomes

After receiving the submitted materials, customs shall review or organize an assessment in accordance with the law and take action based on the following scenarios. A Notice of Customs Inquiry/Assessment Results for Export Control of Dual-Use Items (Annex 2) will be issued.

Determination	Outcomes
No License Required	The enterprise will be notified and allowed to proceed with the subsequent export procedures.
License Required	The goods will not be released and will be handled following relevant regulations.
Uncertain Classification	Customs will request technical identification from the national authority. The final handling of the goods will be based on the identification results.