Ministry of Commerce Addresses Changes to China’s Export Technology Restrictions List

This document discusses the “Catalog of technologies Prohibited and Restricted from Import and export” issued by the Ministry of Commerce and the Ministry of Science and Technology in China, along with its subsequent revisions.

Here’s a breakdown of the key points:

1. Purpose and Context of the Catalog:

The Catalog was first issued in 2001 and has been revised in 2008,2020,and 2023.
Its purpose is to adapt to technological development, improve technology trade management, safeguard national economic security and development interests, and promote international economic and technological cooperation.
China aims for high-level opening up, facilitating the cross-border flow of innovative factors, and integrating into the global innovation network.
China expresses willingness to strengthen technological exchanges and cooperation globally to contribute to economic stability and human welfare.

2. Key Adjustments in the Latest Revision:

The latest adjustment involved soliciting opinions from various stakeholders. The main changes are:

Deletion of Entries:
One prohibited technical entry for traditional chinese construction technology was deleted to facilitate the global sharing of China’s construction technology.
Two restricted technical entries were also deleted.
Addition of a Restricted Entry:
Battery positive electrode material preparation technology has been added as a restricted item. This includes specific technologies related to lithium iron phosphate and raw material preparation for positive electrodes.
This inclusion is to coordinate development and safety, as these technologies are increasingly used in sensitive fields, promoting their safe and sustainable submission.
Modification of a restricted Entry:
Non-ferrous metal metals metallurgy technology has been modified.
This includes adding new control points for lithium extraction technologies (from spodumene and brine) and metal lithium preparation technologies.
The control points for extraction of metal gallium technology have also been modified.
These adjustments reflect technological development and changes.

3. Legal and Compliant Technical Exports:

Definition of Technology export: Transferring technology from China to abroad through trade, investment, or economic and technological cooperation.
Compliance Requirements:
Prohibited Technologies: Cannot be exported. restricted Technologies: Require licenses for export. Exports are not allowed without permission.
Freely Exported Technologies: Require contract registration management.
* Procedures: Business entities must comply with the “regulations” and “Regulations on the Management of…” (the sentence is incomplete but implies further regulations) for export licenses, contract registration, and other procedures.

In essence, the document outlines China’s approach to managing technology exports, emphasizing a balance between promoting innovation and cooperation with safeguarding national interests and security. The recent adjustments reflect this ongoing effort to adapt to evolving technological landscapes.

What specific dual-use technologies now face increased export scrutiny under the revised Export Control List?

Understanding the Recent Adjustments

On July 15, 2025, the Ministry of Commerce (MOFCOM) of the People’s Republic of China announced revisions to its export Control List for Technologies.These changes, impacting a range of industries from semiconductors to advanced materials, represent a significant shift in China’s approach to technology export controls. The updates aim to balance national security concerns with the continued growth of its high-tech sector and international trade. This article breaks down the key modifications, their implications for businesses, and strategies for navigating the new landscape.

Key Changes to the Export Control List

The revised list focuses on several key areas. While the full details are extensive, here’s a summary of the most impactful changes:

Expanded Scope of Dual-Use technologies: The definition of “dual-use” technologies – items with both civilian and military applications – has been broadened. This means more technologies are now subject to export licensing requirements. Specifically, advancements in areas like artificial intelligence (AI), quantum computing, and biotechnology are facing increased scrutiny.

Stricter Controls on Semiconductor Manufacturing Equipment: Export controls on equipment used in the production of advanced semiconductors (below 14nm) have been tightened. this includes lithography systems, etching machines, and other critical manufacturing tools. This builds upon previous restrictions implemented in 2023.

New Restrictions on Advanced Materials: Certain advanced materials, including high-performance alloys, composite materials, and specialized chemicals, have been added to the control list. These materials are often used in aerospace, defense, and other sensitive industries.

Refined licensing Procedures: MOFCOM has streamlined some licensing procedures for less sensitive technologies while simultaneously increasing the complexity for those deemed strategically critically important. This tiered approach aims to reduce bureaucratic hurdles for routine exports while maintaining robust control over critical technologies.

Clarification of End-Use Restrictions: The updated regulations provide clearer definitions of prohibited end-uses, such as activities related to weapons of mass destruction or military intelligence.

Implications for Businesses

These changes have far-reaching implications for companies operating in or trading with China.

Increased Compliance Burden: Businesses involved in the export of controlled technologies will face a heavier compliance burden. This includes conducting thorough due diligence on customers, obtaining necessary export licenses, and maintaining detailed records. Export compliance is now paramount.

Supply Chain Disruptions: The restrictions on semiconductor manufacturing equipment could exacerbate existing supply chain disruptions, particularly for companies reliant on Chinese suppliers. Semiconductor supply chain resilience is a growing concern.

Impact on R&D Activities: The controls on advanced materials and technologies could hinder research and growth (R&D) activities for companies operating in China.Technology transfer is now under increased observation.

Potential for increased costs: The need for export licenses and compliance measures will likely increase costs for businesses.

Geopolitical Considerations: These changes are occurring within a broader context of geopolitical tensions, particularly between China and the united States. businesses need to be aware of the potential for further escalation and adjust their strategies accordingly.

Navigating the New Regulations: Practical Tips

Here are some steps businesses can take to navigate the new regulations effectively:

1. Conduct a Comprehensive export Control Assessment: Identify all technologies and products that may be subject to the new restrictions.
2. Review Existing Export Licenses: Ensure that existing licenses are still valid and compliant with the updated regulations.
3. Strengthen Due Diligence Procedures: Implement robust due diligence procedures to screen customers and identify potential red flags.
4. Develop a Compliance Program: Establish a comprehensive export compliance program that includes training, record-keeping, and internal audits.
5. Engage with Legal Counsel: Seek advice from legal counsel specializing in export control regulations.
6. Monitor Regulatory Updates: Stay informed about any further changes to the export Control List. MOFCOM regularly updates its regulations.
7. Explore Alternative Sourcing Options: Diversify your supply chain to reduce reliance on single sources.

Case Study: Impact on the AI Sector

The increased scrutiny on AI technologies is already being felt by companies in the sector. Several US-based AI firms have reported delays in obtaining licenses for exporting AI models and related software to Chinese customers. This has led some companies to reconsider their business strategies in China, focusing on domestic markets or seeking alternative export destinations. This highlights the importance of proactive risk assessment and contingency planning.

Resources for Further Information

Ministry of Commerce (MOFCOM): http://english.mofcom.gov.cn/

China’s Export Control List: (Available on the MOFCOM website – direct link subject to change)

U.S. Bureau of Industry and Security (BIS): https://www.bis.doc.gov/ (For understanding the broader geopolitical context)

Benefits of Proactive Compliance

Investing in robust export compliance isn’t just about avoiding penalties; it offers several benefits:

Reduced Risk: Minim