Hello, this is Ryuta Hamamoto from TIMEWELL. People just starting export control keep asking me the same plain question: "What is China's dual-use catalogue, really?"
On December 31, 2025, the Ministry of Commerce of the PRC (MOFCOM) and the General Administration of Customs published the "2026 Dual-Use Items and Technologies Import/Export License Management Catalogue" as Announcement 2025 No. 91. It took effect January 1, 2026. The prior Announcement 2024 No. 67 (the 2025 catalogue) is abolished.
Think of this catalogue as China's counterpart to the U.S. Commerce Control List (CCL), Annex I of EU Dual-Use Regulation 2021/821, and Appended Table 1 of Japan's Export Trade Control Order. Same job, different book. Below I walk through the new entries, how semiconductors and AI are handled, and a side-by-side with the U.S., EU, and Japanese lists, sticking to primary facts.
Screening an actual transaction once you have read the catalogue: We publish a fill-in screening sheet for China-related transactions, covering the Export Control Law and the Dual-Use Items Export Control Regulations, the critical-mineral announcements (gallium, germanium, graphite, antimony, tungsten, rare earths, helium) and the four counterparty-list systems (Control List, Watch List, Unreliable Entity List and the countermeasure list). It is a procedure for what to verify before a deal rather than a list of names, so the completed sheet doubles as the record behind your internal approval and your explanation to a counterparty. Being listed is a regulatory designation, not a judgment about the company. → Download the China-Related Transactions Screening Sheet (Free; registration with your company name and work email address is required.)
What You Will Get From This Article
- The full picture of Announcement 2025 No. 91 (1,122 export lines, 151 import lines, effective date, what is abolished)
- Main newly added items (tungsten, molybdenum, seven rare-earth elements, UF6-resistant polymers, and others)
- How semiconductors are handled (14 nm and below / 256-layer and above memory / military AI end uses)
- A parallel comparison with the U.S. CCL, EU Annex I, and Japan's Appended Table 1
- How to read the catalogue through the common yardstick of Wassenaar, NSG, MTCR, and AG
- Five practical steps for Japanese companies
Three Terms to Learn First
Export-control writing is jargon-heavy. Lock in three terms and the rest gets easier.
Dual-Use Item
Goods, software, and technology that can serve both civilian and military end uses. In Chinese, "两用物项." High-performance machine tools, infrared sensors that can feed night-vision systems, and cryptographic modules are typical examples. These are not "military goods as such." Dual-use lists sit at the center of export-control systems worldwide.
HS Code / Customs Commodity Number
The Harmonized System (HS) is the World Customs Organization's goods-classification code — six digits worldwide. Countries add national subdivisions. China's "customs commodity number" runs to ten digits. China's dual-use catalogue is written in a two-part structure of "item description" plus "customs commodity number," which ties cleanly to customs clearance decisions.
Catalogue
In China, a "catalogue" is a list of items that require an export (or import) license. Unlike the U.S. CCL or Japan's Appended Table 1, which address exports only, the Chinese version packages both export-license targets (1,122 lines) and import-license targets (151 lines) in the same volume.
Overview of Announcement 2025 No. 91
| Item | Content |
|---|---|
| Title | 2026 Dual-Use Items and Technologies Import/Export License Management Catalogue |
| Issuing authorities | Ministry of Commerce of the PRC / General Administration of Customs |
| Announcement number | MOFCOM / GACC Announcement 2025 No. 91 |
| Date of publication | December 31, 2025 |
| Effective date | January 1, 2026 |
| Abolished | Announcement 2024 No. 67 (2025 catalogue) |
| Export-license targets | 1,122 lines |
| Import-license targets | 151 lines |
| Page count | 168 pages (2025 edition: 161 pages; about +7 pages) |
| New additions | About 70–85 lines (range depends on the source) |
Legal bases include the Export Control Law of the PRC (effective December 2020), the Regulations on Export Control of Dual-Use Items (effective December 1, 2024), MOFCOM / GACC Order 2005 No. 29, the Dual-Use Export Control Catalogue (November 2024), and the "PRC Customs Import and Export Tariff Schedule (2026 Edition)." This is an annual license-base reorg, not a rewrite of the architecture. Item additions and adjustments track the tariff schedule revision.
Category Layout
The 2026 catalogue is organized in these categories:
- Nuclear dual-use items (NSG-aligned)
- Missile-related items and technology (MTCR-aligned)
- Biological dual-use items (AG biological-aligned)
- Chemicals (monitored chemicals + related chemicals; CWC + AG-aligned)
- Commercial cryptography products (Wassenaar-aligned)
- Aviation-related technology
- Critical mineral resources (tungsten, molybdenum, rare earths, gallium, germanium, graphite, antimony, and others)
- Semiconductor-related items and technology
Category names and order do not match the U.S. CCL, EU Annex I, or Japan's Appended Table 1 one-for-one, but tying them to Wassenaar, NSG, MTCR, and AG shows that essentially the same functional domains are covered.
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Organizing the New Additions
Main additions confirmed from public materials. Many were first controlled by individual announcements during 2025 and then systematically absorbed into the annual catalogue.
Metals and Materials
- Heavy tungsten-nickel alloys: Controls oriented toward use as kinetic-energy penetrators in missile systems.
- Missile-related molybdenum powder: Oriented toward use as missile thermal shielding material.
- Solid tungsten: Listed independently as a form distinct from powder and alloys.
- Seven medium/heavy rare-earth elements including samarium systems: Metals, oxides, alloys, compounds, mixtures, and magnet materials of samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium (reflecting content first added by Announcement No. 18 of April 2025).
Nuclear-Related
- UF6-resistant fluorinated hydrocarbon polymers: Materials that withstand UF6 (uranium hexafluoride) in gas centrifuge systems. Polymers were added alongside stainless steel, aluminum, and nickel-based alloys (Ni content 60% or more) already covered in the 2025 edition. An NSG-followed domain.
Chemicals
- Additional drug-precursor chemicals: In the chemicals chapter, the scope of precursors convertible to narcotics manufacture was expanded. This is a separate layer from CWC monitored chemicals.
Adjustments and Clarifications
- HS tariff number (customs commodity number) revisions for existing items, aligned with the "PRC Customs Import and Export Tariff Schedule (2026 Edition)."
- Clarification of item descriptions: Minor wording fixes and terminology alignment.
- Updated legal-basis references: Unified to the Export Control Law and the Dual-Use Export Control Regulations.
Relationship to Related 2025 Announcements
The 2026 catalogue systematically absorbs individual announcements issued during 2025:
- Announcement No. 10 (2025): Tungsten, tellurium, bismuth, molybdenum, indium-related
- Announcement No. 18 (2025): Seven medium/heavy rare-earth elements
- Rare-earth-related announcements from April 2025 onward: Rare-earth refining technology, related equipment, and extraterritorial application to products with 0.1% or more Chinese-origin content
In practice, I read it this way: controls dropped via individual announcements through mid-year get consolidated into the catalogue at year-end.
Semiconductor Focus Controls
This is the section semiconductor officers care about most. China's catalogue does not mirror the fine numerical-spec classification the U.S. CCL uses for semiconductors. Review is case-by-case, driven by end use.
Representative end uses MOFCOM treats as case-by-case individual review:
| Domain | Examples subject to individual review |
|---|---|
| Logic semiconductors | Chips at process nodes of 14 nm or below |
| Memory semiconductors | Memory chips such as 3D NAND at 256 layers or above |
| AI | Artificial-intelligence end uses that may involve military end use or end users (training GPUs, datasets, some model weights) |
Applicants must disclose detailed end use and end user. The coverage is close to ECCN 3A090 / 4A090 (AI semiconductors) on the U.S. CCL, but China's design writes "14 nm" and "256 layers" into the text and then shifts determination into individual review.
Certain quantum computing, quantum communications, and quantum sensing items and technologies are also placed in categories. Cryptography-related items operate in parallel with the commercial cryptography export-control list — a structure broadly aligned with Wassenaar Cat. 5 Part 2.
Parallel Comparison with the U.S. CCL, EU Annex I, and Japan's Appended Table 1
If I had to pick one habit that saves time, it is this: do not read China's catalogue in isolation. Line up the four regimes.
Regime Overview
| Regime | Authority | Function | Structure |
|---|---|---|---|
| China dual-use catalogue (2026) | MOFCOM / GACC | Lists import and export license targets | Item description + 10-digit customs commodity number |
| U.S. CCL (Commerce Control List) | BIS (Commerce) | Classifies export-license targets by ECCN | 10 categories × 5 product groups |
| EU Annex I (Reg. 2021/821) | European Commission | Common export-control items for member states | 10 categories |
| Japan Appended Table 1 of the Export Trade Control Order | METI | Organizes list-controlled items into 15 items | Items 1–15 |
Category Parallel Mapping
| China category | U.S. CCL | EU Annex I | Japan Appended Table 1 |
|---|---|---|---|
| Nuclear dual-use | Cat. 0 | Cat. 0 | Item 2 |
| Chemical / biological | Cat. 1 | Cat. 1 | Items 3 and 3-2 |
| Materials processing | Cat. 2 | Cat. 2 | Item 5 |
| Electronics | Cat. 3 | Cat. 3 | Item 7 |
| Computers | Cat. 4 | Cat. 4 | Item 8 |
| Communications / information security | Cat. 5 | Cat. 5 | Item 9 |
| Sensors / lasers | Cat. 6 | Cat. 6 | Item 10 |
| Aerospace / propulsion | Cat. 9 | Cat. 9 | Item 14 |
Category numbers align this closely because all four regimes are designed to map to the multilateral export-control regimes. China stated in 2004 a policy of referencing MTCR guidelines. It is not an AG member, but aims for equivalent chemical and biological control standards and implements the CWC framework.
Three Operational Differences
The lists do similar jobs; day-to-day operations do not. Three points for export-control officers:
- Imports and exports in one volume. China packages 1,122 export-license lines and 151 import-license lines in the same catalogue. The U.S. CCL, EU Annex I, and Japan's Appended Table 1 are export-side only.
- End-use review over fine numerical classification. China has relatively fewer semiconductor-ECCN-style numerical cutoffs, and a higher share of individual review under end-use language such as AI end uses that may involve military end use or end users.
- Control List and Watch List operations. Operations of the Control List (supply-prohibition targets) and Watch List (additional-review targets) have been strengthened recently. Detail is in Complete Guide to China's Export Restrictions Toward Japan.
Common Base in Multilateral Regimes
Why do the lists look similar if U.S.–China relations are tense? Dual-use management still uses Cold War-era multilateral export-control regimes as a shared yardstick.
| Regime | Main targets | China's involvement |
|---|---|---|
| WA (Wassenaar Arrangement) | Conventional arms and dual-use (including cryptography) | Not a member; references corresponding lists |
| NSG (Nuclear Suppliers Group) | Nuclear materials and related equipment | Member since 2004 |
| MTCR (Missile Technology Control Regime) | Missiles and UAVs | Not a member; stated reference to guidelines in 2004 |
| AG (Australia Group) | Chemical and biological weapons-related | Not a member; aims for equivalent standards |
| CWC (Chemical Weapons Convention) | Chemicals (monitored chemicals) | Member |
China mixes membership and non-membership, but the item lists themselves are assembled to map to these regimes. Conversely, anyone fluent in the U.S. CCL, EU Annex I, or Japan's Appended Table 1 can read China's catalogue by decomposing "this is MTCR," "this is NSG," and the structure snaps into focus.
Impact on Japanese Companies
How this lands on your desk depends on industry and function. Early 2026 also brought Control List and Watch List measures involving Japanese companies (Announcements No. 1, No. 11, and No. 12). Read those together with the catalogue (timeline in Complete Guide to China's Export Restrictions Toward Japan). List placement is a regulatory designation under Chinese law; it is not, by itself, a judgment on any company's character.
Semiconductor Manufacturing Equipment and Materials
- Nodes at 14 nm and below, memory at 256 layers and above, and AI end uses that may involve military end use or end users sit under individual review. Equipment and materials both need tighter end-use / end-user disclosure than before.
- For maintenance and spare-parts supply on equipment for Chinese domestic customers, re-check license need when catalogue items are included.
AI and Data Centers
- Training GPUs, training datasets, and some model weights may become individual-review targets.
- For models and training data operated by a Chinese legal person, that Chinese entity can also sit on the export side. Check both directions, not only your inbound supply chain.
Rare Earths, Tungsten, Molybdenum
- Screen BOMs for Chinese-origin tungsten, molybdenum, the seven rare-earth elements, gallium, germanium, graphite, and antimony.
- Extraterritorial application to foreign-made products with 0.1% or more Chinese-origin controlled content came in through the April and October 2025 rare-earth announcements. It rides as an accompanying rule, not as text inside the catalogue body. Detail is in China Rare Earth Export Control Map.
Cryptography and Communications Equipment
- Commercial cryptography products remain under joint jurisdiction of the cryptography authority and MOFCOM. Confirm destination and end use in light of the Wassenaar Cat. 5 Part 2 correspondence.
Five Practical Steps
Actions a new officer can start this week.
Step 1: BOM Inventory for Your Products
Confirm, item by item, whether Chinese-origin parts and materials are included. Tungsten, molybdenum, the seven rare-earth elements, UF6-resistant materials, and chemicals near drug precursors are representative checks.
Step 2: Control Determination Against the 2026 Catalogue
For items you already determined under the 2025 edition, re-run the call against HS tariff number updates and description clarifications. No HS code does not mean uncontrolled. Description matches put the item in scope. Always do description-based matching.
Step 3: End-User Certificate Posture with Chinese Domestic Suppliers
Obtain and update End-User Certificates that state civilian end use from Chinese domestic suppliers. Prepare written-assurance templates with Control List / Watch List response in view.
Step 4: Review Transaction Flows via Chinese Subsidiaries and Agents
Only legal persons registered in China with a Unified Social Credit Code can be applicants. Overseas legal persons need application routes through Chinese domestic agents or affiliates.
Step 5: Consider Automation and AI Screening
When multi-entity list updates land repeatedly, pure manual control determination and counterparty screening stops scaling. If I had to pick one internal proposal for a stretched team, it would be AI-assisted matching with a human final check.
Common Misconceptions / FAQ
Q1. How many lines were added in the 2026 edition?
Public sources say "about 70–85 lines" — a range. Counting methods differ by source; a definitive count requires counting the actual catalogue. Page count rose from 161 to 168 — about seven pages.
Q2. If no HS code (customs commodity number) is written in the catalogue, is the item uncontrolled?
No. If the item description matches, a license is required regardless of whether an HS code is shown. Customs matches on description.
Q3. Is the 0.1% extraterritorial rule written in the catalogue body?
No. The catalogue body is an item list; the extraterritorial rule was set in the April and October 2025 rare-earth and related individual announcements. Read the catalogue together with accompanying rules.
Q4. Can a Japanese company's Chinese legal person be an applicant?
Yes, if registered in China with a Unified Social Credit Number. Overseas legal persons need a Chinese domestic agent.
Q5. How does this differ in substance from the U.S. CCL?
Three operational differences: (1) China folds import licenses into one catalogue; (2) fewer fine numerical semiconductor ECCN-style specs, higher share of end-use case-by-case judgment; (3) stronger recent use of Control List / Watch List operations, including accompanying extraterritorial rules. The item-list job itself is comparable.
Q6. Can anyone use a general license?
No. General licenses (covering multiple transactions) are for reliability-reviewed operators and cannot be used for exports to Control List entities. Destinations on the Control List require individual license applications plus additional documents. Again, list placement is a regulatory status, not a moral label.
Latest Developments as of July 2026
The 2026 catalogue's inclusion of critical minerals such as tungsten, molybdenum, and the seven medium/heavy rare-earth elements also meshes with later Japanese moves. The 16th Japan–India annual summit on July 2, 2026 produced a joint declaration on economic-security cooperation in five fields: semiconductors, critical minerals (rare earths), clean energy, ICT (subsea cables), and pharmaceuticals, with an investment framework on the order of about 2 trillion yen (Japan–India summit press conference (Prime Minister's Office of Japan, July 2026)). Read China's catalogue update together with sourcing diversification, not in isolation. My view is that critical-mineral BOM inventory will matter more on both the compliance and alternative-sourcing sides. Detail is in the Japan–India summit and economic security.
Summary
If you only act on one thing this week, re-run control determination on Chinese-origin BOM lines against the 2026 catalogue. The rest of the map looks like this:
- MOFCOM / GACC Announcement 2025 No. 91 published December 31, 2025; effective January 1, 2026.
- Export-license targets: 1,122 lines. Import-license targets: 151 lines. New additions: about 70–85 lines. Page count: 161 to 168.
- Addition focus: tungsten-nickel alloys, molybdenum powder, solid tungsten, seven medium/heavy rare-earth elements, UF6-resistant fluorinated hydrocarbon polymers, additional drug-precursor chemicals.
- Semiconductors: 14 nm and below, 256-layer and above memory, and AI end uses that may involve military end use or end users under individual review. Design is end-use-based rather than fine U.S. CCL-style numerical classification.
- Comparable in function to the U.S. CCL, EU Annex I, and Japan's Appended Table 1, sharing Wassenaar, NSG, MTCR, and AG as a common base.
- The 0.1% extraterritorial rule is not in the catalogue body; it rides under accompanying rare-earth announcements from April and October 2025.
- Practice path: BOM inventory, control determination, end-user certificates, application-flow review, then automated screening support.
Related Articles
- China Rare Earth Export Control Map (2025–2026)
- Complete Guide to China's Export Restrictions Toward Japan (40-Company Lists, Control List, Watch List)
- U.S. EAR, China, and EU — Three-Regime Simultaneous Impact Guide
- U.S.–China AI Semiconductor Calendar (2024–2028)
Introducing the Export-Control AI Agent TRAFEED
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References
- MOFCOM / GACC, "2026 Dual-Use Items and Technologies Import/Export License Management Catalogue" (Announcement 2025 No. 91, December 31, 2025) https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_c03d1e511b2b486e829d68e8f1422aff.html
- MOFCOM spokesperson Q&A (December 31, 2025) https://www.mofcom.gov.cn/syxwfb/art/2025/art_3fefce5ab85f4156844e72c16bbd5acd.html
- 2026 Catalogue of Goods Subject to Export License Management https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_0ac7e2005ff04c488daa3add8972ea36.html
- 2026 Catalogue of Goods Subject to Import License Management https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_5ffcf701f72e4fc6b16f274c2e5b80f8.html
- MOFCOM Dual-Use Import/Export Control Business Application Platform https://ecomp.mofcom.gov.cn
- CISTEC, "China Announces Dual-Use Items and Technologies Import/Export License Management List (2026 Edition)" (January 8, 2026) https://www.cistec.or.jp/service/keizai_anzenhosho/china/data/20260108.pdf
- CISTEC China regulation page https://www.cistec.or.jp/service/keizai_anzenhosho/china/china_page.html
- JETRO Beijing Office, "Overview of the Dual-Use Export Control List" https://www.jetro.go.jp/ext_images/_Reports/01/c4f5a32439d71ff8/20240038_04.pdf
- ChemLinked, "China Issues 2026 Catalogue of Dual-Use Items and Technologies Subject to Import and Export Licensing" https://chemical.chemlinked.com/news/chemical-news/china-issues-2026-catalogue-of-dual-use-items-and-technologies-subject-to-import-and-export-licensing
- ITTC Net, "China Updates Dual-Use Export Control Catalogue for 2026" https://ittcnet.org/insights/china-updates-dual-use-export-control-catalogue-for-2026/
- China Briefing, "Dual-Use Item and Technology Catalogue 2025 vs 2026 Comparison" https://www.china-briefing.com/news/wp-content/uploads/2026/02/Dual-Use-Item-and-Technology_Catalogue_2025vs2026_Comparison.pdf
- Bird & Bird, "Chinese Export Controls: MOFCOM targets Japanese entities with new dual-use restrictions" https://www.twobirds.com/en/insights/2026/china/chinese-export-controls-mofcom-targets-japanese-entities-with-new-dual-use-restrictions
- Jones Day, "China Imposes Extraterritorial Export Control Measures Over Rare Earth Items" https://www.jonesday.com/en/insights/2025/10/china-imposes-extraterritorial-export-control-measures-over-rare-earth-items
- King & Wood Mallesons, "China's Export Control Regime and Practical Measures for Dual-Use Items" (November 4, 2025) https://www.kwm.com/jp/ja/insights/latest-thinking/publication/ChinasExportControlRegimeandPracticalMeasuresforDual-UseItems_20251104.html
- CSET, "China's Dual-Use Export Control Regulation (English translation)" https://cset.georgetown.edu/publication/china-dual-use-export-control-regulation/
