At the start of 2026, the import and export sector saw significant policy adjustments. On January 1, the 2026 “Catalogue for the Administration of Import and Export Licenses for Dual-Use Items and Technologies” officially came into effect. Just five days later, the Ministry of Commerce issued Announcement No. 1, imposing strict controls on the export of relevant dual-use items from Japan. The combined effect of these two policies directly impacted the import and export business of companies in multiple sectors, including rare earths, chemicals, and electronic equipment, significantly raising compliance thresholds.
The new regulations have three key highlights, directly affecting business operations. First, the scope of control has been significantly expanded, with 1005 items now under regulation. The new “Catalogue” expands the export control list for dual-use items to 1005 items, divided into two core categories.
The first category covers 846 items, including chemicals related to the manufacture of narcotics and chemical weapons, rare earth elements (gallium, germanium, antimony, etc.), electronics, sensors, and aerospace equipment. The second category includes 159 items and technologies related to nuclear materials and nuclear reactors, covering the entire industrial chain from basic materials to high-end technologies. Both SMEs and large foreign trade enterprises need to re-evaluate whether their exported products fall within the scope of control. Secondly, controls on Japan have been upgraded, with a complete ban on military use. The Ministry of Commerce’s Announcement No. 1 of 2026 clearly stipulates that, effective immediately, the export of all dual-use items to Japanese military users or for military purposes is prohibited, and any organization or individual is prohibited from transferring related items originating in China to relevant Japanese parties; violators will be held legally responsible. This policy is in response to Japan’s recent military expansion actions and erroneous statements. Relevant enterprises must strictly verify the export destination, end user, and intended use to avoid crossing the policy red line.
Furthermore, the licensing management is more detailed, and the processing procedures are more standardized. The new regulations clarify that the export of dual-use items will be subject to three modes: single license, general license, or registration and information filling. A single license is valid for no more than one year and is limited to one specific export; a general license is valid for a maximum of three years and allows for multiple exports; in certain specific situations (such as the re-shipment of exhibits, parts repair, etc.), export certificates can be obtained through registration and information filling. At the same time, the license application process is paperless, and enterprises need to submit applications through the unified platform of the Ministry of Commerce’s business system (https://ecomp.mofcom.gov.cn).
For enterprises, there are four compliance practice guidelines to avoid risk pitfalls. The first step is to conduct a self-verification to clarify the product ownership.
Exporters must proactively verify the performance indicators and main uses of the goods, technologies, and services they intend to export to determine whether they fall under the scope of dual-use items control. If unsure, they can consult the Ministry of Commerce under the State Council and submit relevant explanatory materials. Special attention should be paid to key controlled categories such as rare earths, chemicals, and drones to avoid violations due to cognitive biases. The second step is to prepare application materials and ensure accuracy. Applying for an export license requires core materials such as the identity certificates of the legal representative and the person handling the application, copies of the trade contract, technical specifications or test reports, and end-user and end-use certification documents (including Chinese translations). Special attention should be paid to: the end-user certificate must be signed and stamped by the responsible person, and the application form and the English and Chinese descriptions of the intended use must be consistent to avoid affecting approval due to material defects. The third step is to closely monitor approval timelines and plan business operations accordingly. The review period for routine license applications is 45 working days. For major matters involving national security and interests, approval from the State Council or the State Council and the Central Military Commission is required, and the time limit is unlimited. Enterprises need to plan their export cycles in advance and allow sufficient approval time to avoid delays in customs clearance due to unresolved license issues. The fourth step is to standardize license usage; changes must follow formal procedures. Exports must strictly adhere to the scope, conditions, and validity period specified in the license. If key elements such as the type of goods, export country, or end-user need to be changed, a new license must be applied for and the original license returned. Changes to non-key elements also require an application, and the original license must be suspended until approval is granted. Licenses must be presented to customs upon declaration; failure to do so will result in denied release. Facing the compliance challenges brought by the new regulations, Xinbida leverages its extensive professional experience in the import and export field to provide enterprises with full-chain support. This includes free interpretation, combining the original text of the 2026 “Catalogue of Dual-Use Items and Technologies Import and Export License Management” to provide customized compliance diagnostic reports for enterprises; process guidance, assisting in sorting out license application materials and avoiding common errors such as “inconsistent application forms” and “incomplete supporting documents”; resource matching, linking with government and enterprise compliance service networks to provide practical support such as license processing progress tracking and assistance with change procedures; and specialized training, explaining the key points of the new regulations and risk control techniques in detail through online public welfare live broadcasts and offline training online. Compliance is the lifeline of import and export business. The refinement and upgrading of the dual-use item control policy in 2026 is both a challenge and an opportunity to regulate industry development. Xinbida will continue to follow policy developments and provide enterprises with professional and efficient compliance solutions to help everyone navigate the complex trade environment steadily and sustainably. Interactive bonus: Reply with “new regulations on dual-use items” via private message to receive the “2026 List of Application Materials for Dual-Use Item Import and Export Licenses” and official filing guidelines! If your company is involved in the export of related categories, please leave a message in the comments section to consult on specific compliance issues, and we will answer the best questions.
