The Zhitong Finance App learned that on October 19, the Ministry of Commerce and the General Administration of Customs announced matters relating to further optimizing export control questions and verification work for dual-use items. According to the announcement, the Ministry of Commerce and the General Administration of Customs continue to optimize questioning and verification work processes, strengthen informatization construction, increase policy promotion guidelines, and support enterprises to improve export compliance systems. When the shipper of the export goods reports for export, if the export license issued by the Ministry of Commerce has not been submitted to the Customs for inspection, and the Customs has evidence that the export goods may fall within the scope of export control of dual-use items, it shall raise a challenge with the shipper of the exported goods and issue a “Customs Challenge Notice Concerning the Export Control of Dual-Use Items”. In questioning, identification or related work, shippers of export goods shall truthfully provide and supplement relevant materials as required, ensure that the content and data are true and reliable, and must not refuse, obstruct, conceal or provide false information.
The original text is as follows:
Ministry of Commerce and General Administration of Customs Notice No. 52 of 2026 promulgated matters relating to further optimization of export control questions and verification of dual-use items
In order to promote compliant trade for enterprises, raise the level of export facilitation for dual-use items, and further improve the standardization, scientific and effectiveness of export control questioning and verification work, in accordance with the “Export Control Law of the People's Republic of China”, “Customs Law of the People's Republic of China”, “Regulations of the People's Republic of China Export Control for Dual-use Items” and other relevant regulations, the relevant matters are now announced as follows:
1. The Ministry of Commerce and the General Administration of Customs continue to optimize questioning and identification work processes, strengthen informatization construction, increase policy promotion guidelines, and support enterprises to improve export compliance systems.
2. When the shipper of the exported goods makes an export declaration, if the export license issued by the Ministry of Commerce has not been submitted to the Customs for inspection, and the Customs has evidence that the exported goods may fall within the scope of export control of dual-use items, it shall raise a challenge with the sender of the exported goods and issue a “Customs Challenge Notice on Export Control of Dual-Use Items” (Annex 1).
3. The shipper of the export goods shall provide the following materials as required within 7 working days from the date of receipt of the “Notice of Customs Challenge on Export Control of Dual-use Items”. The materials must be stamped with an official seal. If the materials are in a foreign language, a Chinese translation is also provided:
(1) Customs declarations, export contracts, invoices, and transport documents certifying the direction of the goods;
(2) A description of the circumstances (including but not limited to stating the performance indicators of the goods, the main uses, and legal and factual reasons for believing that they are not covered by export controls, etc.);
(3) Relevant technical data proving the properties of the goods (if any, inspection reports should be provided together);
(4) Other materials required.
4. After receiving the materials provided by the shipper of the exported goods, the Customs makes a determination. If necessary, the General Administration of Customs may submit an organizational inspection to the Ministry of Commerce, dispose of them separately in accordance with the law according to the following circumstances, and issue a “Notice of Customs Questioning Results of Dual-Use Items Export Control” (Annex 2).
(1) If it is not a dual-use item, continue to go through customs clearance procedures;
(2) If it is a dual-use item, dispose of it in accordance with regulations;
(3) In other circumstances, it shall be handled in accordance with relevant requirements.
5. After receiving the customs inspection request, the Ministry of Commerce organizes experts to inspect the items and can send them to the relevant agencies for inspection and testing if necessary.
6. During the questioning and inspection period, the customs will not release the relevant export goods. Where the shipper of export goods applies to separate and dispose of other goods unrelated to the contested goods under the same customs declaration, it may go through separate customs clearance procedures after customs evaluation, investigation and approval.
7. The customs shall complete the challenge determination or submit an organizational inspection to the Ministry of Commerce within 15 working days from the date of receipt of all materials provided by the consignor of the goods. The Ministry of Commerce makes an identification conclusion within 15 working days from the date of receipt of complete organizational identification materials.
The time required for the shipper of the export goods to submit or supplement materials, inspection and inspection of the contested goods, etc. is not included in the above time limit; special circumstances such as serious or difficult circumstances are not limited by the time limit set forth in the preceding paragraph.
8. In questioning, identification or related work, shippers of export goods shall truthfully provide and supplement relevant materials as required, ensure that the content and data are true and reliable, and must not refuse, obstruct, conceal or provide false information.
9. Where dual-use items are exported through channels such as cross-border e-commerce, passenger transport, mail, express delivery, etc., please refer to this Notice.
10. The Ministry of Commerce and the General Administration of Customs are responsible for explaining the identification and questioning work involved in this notice.
This notice came into effect on the date of publication, and the “Notice Concerning Matters Relating to Customs Questions Concerning Export Control of Dual-Use Items” (General Administration of Customs Notice No. 123 of 2025) was abolished at the same time.
Attachment: 1. Customs Challenge Notice for Dual-Use Items Export Control
2. Notification of customs dispute results for export control of dual-use items
Ministry of Commerce General Administration of Customs
October 19, 2026
This article was selected from the “Ministry of Commerce” official website, Zhitong Finance Editor: Feng Qiuyi.