Following the release of the Regulations on the Export Control of Dual-use Items (ECR), the China’s Ministry of Commerce (MOFCOM), as anticipated, published the Dual-use Items Export Control List (Control List) which will take effect together with the ECR on December 1, 2024. Please refer to our previous article about the China Export Control Regulations.
The Control List adopts an Export Control Classification Number (ECCN)-like coding system and clarifies several important
concepts, as well as application of the ECR and the Control List.
Consolidated List and New Coding System
First of all, as expected, the Control List consolidates the existing 10 plus control lists that are published under different regulations.
More importantly, the Control List creates a five-character coding system that is similar to the ECCN under the US Export
Administration Regulations (US EAR), and the EU list of dual-use items. The meanings of the five characters are also similar to
ECCN and EU control list, which will make it much easier to reference and compare in international trade.