New Rules on Dual-Use Export Queries: Clear Deadlines and Separate Customs Clearance for Unrelated Goods
On October 19, 2026, the Ministry of Commerce and the General Administration of Customs issued Announcement No. 52 of 2026, revising the inquiry and identification procedures for dual-use item export controls, effective the same day. The new rules specify deadlines for businesses to submit documents, for Customs to make determinations, and for the Ministry of Commerce to conduct identification. They also allow other goods on the same customs declaration that are unrelated to the goods under inquiry to undergo customs clearance separately, subject to Customs approval.
For businesses shipping from China, these rules mainly concern goods that Customs suspects may fall within the scope of dual-use item export controls. They also apply, by reference, to exports involving dual-use items through channels such as cross-border e-commerce, passenger baggage, mail, and express shipments.
Submit documents within 7 working days of receiving an inquiry notice
If an export license issued by the Ministry of Commerce is not presented at the time of export declaration, and Customs has evidence that the goods may fall within the scope of dual-use item export controls, Customs must issue the consignor a Customs Inquiry Notice on Dual-Use Item Export Controls.
Within 7 working days of receiving the notice, the consignor must provide the following as required:
- The customs declaration, export sales contract, invoice, and transport documents proving the destination of the goods;
- A written explanation covering the goods' performance specifications, primary uses, and the legal and factual grounds for considering them outside the scope of export controls;
- Technical documents proving the nature of the goods, together with any available inspection and testing reports;
- Any other required documents.
The documents must bear the company's official seal. Documents in foreign languages must be accompanied by Chinese translations. The consignor must provide truthful information, submit supplementary documents as required, and ensure that all content and data are accurate and reliable.
Separate deadlines apply to Customs determinations and Ministry of Commerce identification
| Stage | Starting point | Processing requirement |
|---|---|---|
| Customs determination following an inquiry | From the date all documents provided by the consignor are received | Complete the determination or request identification by the Ministry of Commerce within 15 working days |
| Identification organized by the Ministry of Commerce | From the date the complete set of documents for identification is received | Issue an identification conclusion within 15 working days |
Time spent by the consignor submitting or supplementing documents, or on inspection and testing of the goods under inquiry, is excluded from these deadlines. Special circumstances, including significant or complex cases, are not subject to these deadlines. The timeframes in the table therefore cannot be used directly to determine release or arrival dates.
Following a Customs determination or organized identification, a Customs Notice of Inquiry Results on Dual-Use Item Export Controls will be issued. If the goods are not dual-use items, customs clearance procedures will continue. If they are dual-use items, they will be handled in accordance with applicable regulations. Other circumstances will be handled according to the relevant requirements.
Unrelated goods may be separated upon application, subject to Customs approval
The relevant export goods will not be released during the inquiry and identification process.
If the same customs declaration includes other goods unrelated to those under inquiry, the consignor may apply to have them processed separately. Following assessment and approval by Customs, those goods may undergo customs clearance separately.
Applying for separate processing does not mean automatic release, nor does it change the review requirements for the goods under inquiry. When arranging shipments, confirm transport plans based on the actual progress of the goods' review.
Effective date and official source
This announcement takes effect on October 19, 2026. General Administration of Customs Announcement No. 123 of 2025, Announcement on Matters Concerning Customs Inquiries on Dual-Use Item Export Controls, is repealed at the same time.
Official text: Ministry of Commerce and General Administration of Customs Announcement No. 52 of 2026. The announcement includes attachments containing the inquiry notice and the notice of inquiry results.
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