What Are China's "Four Military Certifications" (军工四证)? A 2026 Guide to Reading the Military Supply Chain — and Screening Chinese Counterparties in Practice

Hello, this is Hamamoto from TIMEWELL. If you have ever run due diligence on a Chinese counterparty, you may have come across the phrase 军工四证 (jūngōng sì zhèng) — the "four military certifications" — in a company brochure or an annual report. In Chinese-language corporate materials it appears all the time, almost casually. Yet outside China, and certainly in Japan and the English-speaking compliance world, there is remarkably little organized explanation of what it actually means. And from the standpoint of someone doing end-user screening for export controls, it is a phrase that carries real weight.

The four military certifications are the collective name for four qualifications and certifications obtained by companies and organizations engaged in the research, development, and production of weapons and equipment in China. Put the other way around: a counterparty that holds them has been officially, institutionally confirmed as part of China's military supply chain. In October 2025, Japan expanded its catch-all export controls to conventional weapons, which means exporters are now asked, more sharply than ever, to judge whether a counterparty is "an end user engaged in the development of weapons." At that moment of judgment, the four military certifications are one of the few objective clues available.

In this article I will walk through what each of the four certifications actually covers, the policy context of military-civil fusion that reshaped them, and how to translate all of this into screening practice at a Japanese — or any non-Chinese — company. If you would first like to know where your own export control program stands before diving in, try our free export-control readiness check. It takes about three minutes.

The Four Certifications at a Glance

The four military certifications consist of: (1) the Weapons and Equipment Quality Management System Certification (武器装备质量管理体系认证, commonly known as the GJB 9001 "national military standard" certification), (2) the Weapons and Equipment R&D and Production Unit Secrecy Qualification (武器装备科研生产单位保密资格), (3) the Weapons and Equipment R&D and Production License (武器装备科研生产许可), and (4) the Equipment Contractor Qualification (装备承制单位资格, a registry-based supplier qualification)[^1]. If you want a one-line summary of their respective roles: quality, secrecy, business license, and delivery eligibility — four gates, each with its own legal basis and its own supervising authority.

Certification	What it examines	Main supervising authority	Notes
Weapons and Equipment Quality Management System Certification (GJB 9001)	Whether the quality management system conforms to military standards	Jointly administered by SASTIND (the State Administration for Science, Technology and Industry for National Defense) and the military's equipment departments	The current standard is understood to be GJB 9001C-2017
Weapons and Equipment R&D and Production Unit Secrecy Qualification	Whether the organization has systems in place to handle state secrets	Level 1: the National Administration of State Secrets Protection and others; Level 2: provincial-level secrecy bureaus	Two-tier system (Level 1 / Level 2) since July 2021
Weapons and Equipment R&D and Production License	Business license for R&D and production of weapons and equipment listed in the license catalogue	Category 1: SASTIND; Category 2: provincial-level departments	Valid for five years; the catalogue itself is non-public
Equipment Contractor Qualification	Eligibility to deliver directly to the military (the procurement side)	Uniformly administered by the Equipment Development Department of the Central Military Commission	Entered into a registry; valid for five years

One important caveat before going further. Not every company involved in China's defense sector holds the full set of four. The equipment contractor qualification, in particular, is an eligibility review required when a company delivers directly to military procurement departments — a downstream component supplier deep in the supply chain may simply not need it[^1]. This cuts both ways: if you can establish which of the four certifications a counterparty holds, you can read, with reasonable confidence, roughly where in the military supply chain that company sits.

The Four Certifications, One by One

Let me take each in turn.

First, the Weapons and Equipment Quality Management System Certification. This regime is grounded in the Regulations on Quality Management of Weapons and Equipment, which provide that a unit that has not passed certification may not undertake the development, production, or maintenance of weapons and equipment. Certification is carried out jointly by SASTIND and the military's equipment departments[^8]. The current standard is GJB 9001C-2017, which was drafted with reference to ISO 9001:2015 and replaced the older GJB 9001B-2009; certification bodies describe it as having been issued in 2017[^8]. A useful mental model is "the military edition of ISO 9001." Because it is a quality management certification, it is the lowest hurdle of the four, and the one demanded most broadly — right down to the far end of the supply chain.

Second, the secrecy qualification. Its formal name is the Weapons and Equipment R&D and Production Unit Secrecy Qualification, and it is the prerequisite for conducting research or production that touches state secrets. Historically it came in three grades: Level 1 (eligible for top-secret, secret, and confidential tasks), Level 2 (secret and confidential), and Level 3 (confidential)[^6]. That changed in 2021. Following the State Council's "separating permits from business licenses" reform, an announcement by the National Administration of State Secrets Protection consolidated the system into two grades — Level 1 and Level 2 — effective July 1, 2021, and new Level 3 applications stopped being accepted. Units undertaking top-secret tasks apply for Level 1; those handling secret or confidential tasks apply for Level 2. Existing Level 3 qualifications remain valid until their certificates expire[^7]. The review structure is split by grade: Level 1 is examined by a review and certification committee formed jointly by the National Administration of State Secrets Protection with SASTIND, the military's equipment departments, and others, while Level 2 is examined by the secrecy bureaus of provinces, autonomous regions, and centrally administered municipalities together with the relevant local authorities[^9].

The feature of the secrecy qualification most worth internalizing is its strict exclusion of foreign capital. Control or direct investment from outside mainland China — a definition that includes Hong Kong, Macau, and Taiwan — is not permitted, and even for indirect investment, the combined shareholding of foreign investors and parties acting in concert with them must not ultimately exceed 20%. On top of that, the legal representative, the actual controller, directors, supervisors, and senior management, as well as personnel handling classified tasks, must not only hold Chinese nationality but must also hold no foreign permanent residency — and must not be married to a person from outside mainland China[^9]. I confess the marriage requirement startled me the first time I read it. But it tells you exactly what this qualification is: an examination of whether the state can trust the entity. A company holding the secrecy qualification should be understood as one that has been institutionally walled off from foreign capital.

Third, the Weapons and Equipment R&D and Production License. Its legal basis is the Regulations on the Administration of Licenses for Weapons and Equipment R&D and Production — Order No. 521 of the State Council and the Central Military Commission — promulgated on March 6, 2008, and effective April 1 of that year. It establishes a licensing regime for R&D and production activities involving weapons and equipment listed in the license catalogue, with theoretical and basic scientific research excluded[^2]. Under the implementing measures issued in 2010, licenses are divided by importance into Category 1 and Category 2: Category 1 applications are received and approved directly by SASTIND, while Category 2 applications are handled by provincial-level departments for defense science, technology, and industry. Licenses are valid for five years[^3]. Notably, holding the secrecy qualification is one of the conditions for applying for this license[^9]. In other words, the four certifications do not sit side by side as independent items — they stack.

Fourth and last, the Equipment Contractor Qualification. This is the eligibility review for delivering directly to the military's procurement side. It is uniformly administered by the Equipment Development Department of the Central Military Commission and implemented by the equipment departments of the individual services and by military representative offices. Units that pass the review are entered into the Registry of Equipment Contractor Units of the Chinese People's Liberation Army, and the qualification is valid for five years. In practice, the application software is obtained from the PLA's whole-military weapons and equipment procurement information portal (weain.mil.cn)[^10]. If it helps, think of it as getting onto the People's Liberation Army's approved supplier register.

The Policy Context: Military-Civil Fusion

The four certifications are not new institutions, but their character has changed substantially over the past decade. The key is military-civil fusion (军民融合, jūnmín rónghé). On March 12, 2015, Xi Jinping declared at the plenary meeting of the PLA delegation to the National People's Congress that military-civil fusion would be elevated to a national strategy, and on January 22, 2017, a meeting of the Politburo of the Chinese Communist Party decided to establish the Central Commission for Integrated Military and Civilian Development, chaired by Xi Jinping himself[^12]. The policy intent is to channel private-sector technology into military demand — and under that policy, the entry barriers around the four certifications have been lowered consistently.

The numbers tell the story. The license catalogue that defines the scope of the Weapons and Equipment R&D and Production License was cut to 755 items in the 2015 edition, published in September 2015 — a reduction of roughly two-thirds from the 2005 edition[^5]. The 2018 edition, jointly issued in December 2018 by SASTIND and the Equipment Development Department of the Central Military Commission, narrowed the catalogue further to 285 items across seven major categories, including missile weapons and launch vehicles — a 62% reduction in licensed items compared with the 2015 edition. Licensing requirements were removed on a large scale for equipment-level and component-level items and for general complete units and electronic components in military electronics[^4]. Every domain where a license was no longer required became a domain that private companies could enter more easily.

Procedural consolidation moved in parallel. From October 1, 2017, the "two certificates in one" (两证合一) reform was fully piloted, merging the equipment contractor qualification review with the GJB 9001 quality management system certification: the GJB 9001 requirements were folded into the qualification review, so that a single examination produces a single certificate — an equipment contractor qualification certificate annotated to confirm conformity with the national military standard. The classification of contractor units was also adjusted from three classes to two, Class A and Class B[^11]. This is why industry practice increasingly speaks of the "three military certifications" (军工三证) rather than four. But do not misread this: the GJB 9001 certification itself has not disappeared. For subcontract suppliers outside the registry, it continues to function as a standalone certification[^11]. Joint review rules were also established for the license and the contractor qualification: Category 1 licenses and contractor qualifications are jointly examined by the relevant departments of SASTIND together with the services' equipment departments, while Category 2 reviews are organized jointly by provincial-level administrative departments[^13].

For screening practice at Japanese companies, the significance of this trajectory is hard to overstate. Lower entry barriers mean that the population of companies which look like ordinary civilian manufacturers — yet may have one foot in the military supply chain — has grown much larger. For a fuller picture of how the boundary between civilian technology and military end use is dissolving, see my article on dual-use technology and military conversion risk; read together, the two pieces should give you a more three-dimensional view.

What This Means for Japanese Companies: Catch-All Controls and the MEU Rule

Let me be explicit about the framing before going further. Holding the four military certifications is not merely legal inside China — it is a qualification the state actively encourages, and it is not, in itself, a signal of illegality. The simplification "a Chinese company with the four military certifications is dangerous" is inaccurate as a matter of practice. The precise meaning for a Japanese company is this, and only this: the certifications are official evidence that the counterparty is institutionally embedded in the weapons and equipment supply chain. The real question is where that evidence plugs into Japan's export control framework.

The first connection point is the catch-all controls. Japan's complementary export controls assess whether goods or technology being exported risk being used in the development of weapons of mass destruction or conventional weapons, based on two objective criteria — the end-use criterion (what the item will be used for) and the end-user criterion (what kind of end user will use it) — plus the "inform" criterion, triggered when the Minister of Economy, Trade and Industry notifies the exporter that a license application is required[^14]. The framework was revised with effect from October 9, 2025, extending the end-use and end-user criteria into the conventional weapons catch-all regime. For exports to non-listed (general) countries, the controls apply to the "specified items" under item 16(1) of Appended Table 1 of the Export Trade Control Order — twelve categories including machine tools, radar, integrated circuits, and aircraft. The concern categories on Japan's End User List were also expanded: "conventional weapons" was added alongside the four traditional WMD categories[^15]. Ahead of the entry into force, METI revised the End User List on September 29, 2025; the revised list covers 835 entities across 15 countries and regions, an increase of 87 entities[^16].

Here is the structural point that matters. Even a company that does not appear on the End User List still falls within the scope of the end-user criterion if it qualifies as "an end user engaged in the development, etc. of weapons." The fact that a counterparty holds the Weapons and Equipment R&D and Production License, or the Equipment Contractor Qualification, is information you cannot ignore when making that determination. Absence from the list is not a clean bill of health.

The second connection point is the U.S. military end user (MEU) rule. On December 23, 2020, the Commerce Department's Bureau of Industry and Security (BIS) published a final rule in the Federal Register creating the MEU List under section 744.21 of the Export Administration Regulations, effective the same day. The initial tranche listed 102 entities — 57 Chinese and 45 Russian[^17]. What must not be overlooked is that BIS itself stated explicitly that the list is not exhaustive, and that exporters retain the obligation to determine whether non-listed parties qualify as military end users[^17]. In other words, under U.S. rules too, list matching alone is not enough. The fact that a counterparty holds the four military certifications is a strong signal supporting an inference of military end-user status, and it belongs in the weighting of your due diligence. For a fuller picture of the MEU List, the Entity List, the SDN List, and how the major restricted-party lists relate to one another, see my complete guide to sanctions lists.

How to Verify — and the Limits of Verification

So how, in practice, do you find out whether a counterparty holds the four military certifications? There are several avenues.

The most reliable, when the counterparty is a listed company, is its disclosure documents. Even for military-related companies, the holding of the four certifications (in practice, often three) is frequently disclosed in prospectuses and annual reports, making these documents a key verification source in the public record[^18]. Going to the original filings on disclosure platforms such as CNINFO (巨潮资讯网) is the basic move. Beyond that, useful sources include procurement notices and supplier information on the PLA's whole-military weapons and equipment procurement portal, award and subsidy announcements published by local governments and industrial parks, and information released by certification bodies. It is not at all rare for a local government to announce, with evident pride, that "a company in our district has obtained the equipment contractor qualification" — and fragments like these can be surprisingly powerful in an investigation.

But it would not be fair to describe the sources without describing the limits. There are three structural walls. First, the license catalogue for the Weapons and Equipment R&D and Production License is itself a non-public document. Consulting it is said to require an inquiry to the local competent authority for defense science, technology, and industry, and there is no way to comprehensively confirm from the outside which licensed items a counterparty holds[^19]. Second, the secrecy qualification: given its nature, no comprehensive public register of qualified units appears to exist. Third, there is the disclosure exemption regime (豁免披露). Military-related companies going public can, with the approval of the competent defense science and technology authority or the stock exchange, obtain exemptions from disclosing counterparty names, product model numbers, prices, technical specifications, and similar details[^18].

What these three walls mean, taken together, is that "we investigated and could not confirm it" does not mean "they do not hold it." Public-source screening is a necessary condition, not a sufficient one. That is precisely why what gets tested is your internal methodology: how you weight the information you did confirm, and what rules you apply to the parts you could not. The fundamentals of end-user verification are covered in my article on end-user screening and customer due diligence — but when the counterparty is a Chinese company, always start from the three limitations described here. Our export control AI agent TRAFEED was built for exactly this task: gathering the scattered fragments of public information and helping you weight them.

Building It into Screening Practice

Finally, let me pull this together into practice. My framing is simple: treat confirmation of the four military certifications not as a go/no-go verdict on the transaction, but as a trigger to deepen verification. If you confirm that a counterparty holds them, first check whether the goods or technology you intend to export fall under list controls, or under the specified items of the catch-all regime. Next, examine the counterparty's business activities, the end use, and its character as an end user one level more deeply than usual. Run the checks against the End User List and the MEU List, of course — but do not treat a non-hit as reassurance. And for any case where the judgment is genuinely close, escalate to your export control officer, without exception. Turn that sequence into a standing process, and the four military certifications stop being a tool for killing deals and become material that raises the quality of your decisions.

That said, tracking Chinese-language disclosure documents and government announcements by hand, continuously, is — let me be honest — a heavy burden. TRAFEED is an export control AI agent aligned with the standards of Japan's Ministry of Economy, Trade and Industry, supporting both item classification (determining whether goods and technology are controlled) and counterparty screening. Its AI classification accuracy exceeds 95% (based on a joint validation study with Okayama University using approximately 30,000 past review records; company data). It holds Japanese Patent No. 7862062 and is currently deployed at more than 20 organizations. Regulatory amendments across jurisdictions are reflected the same day, and a counterparty's concern level is visualized in five seconds. Behind it runs a knowledge graph of more than 200 million records — linking 90 million academic papers, 100 million patents, and 300,000 researchers — which is what supports the work of sketching a counterparty's outline from fragments of public information. One thing I want to stress, though: the final classification decision and the final call on whether to proceed with a transaction always rest with your company's export control officer. AI is a tool for making judgments faster and more complete — it is not, and cannot be, the bearer of responsibility.

The four military certifications are, as a Chinese institution, a rationally designed system of entry control. How a Japanese company should read them is a separate question. With the October 2025 expansion of the conventional weapons catch-all controls, sharp-eyed scrutiny of end users is no longer a nice-to-have — it is part of legal compliance. It is worth taking stock, once, of whether any company on your counterparty list holds the four military certifications. If you are unsure how to proceed, Book a consultation — we help with everything from explaining the institutional landscape to building your internal screening program, always from a practitioner's point of view.

References

[^1]: A Journey to the Stars and the Sea: Legal Due Diligence and Compliance Essentials for Commercial Launch Vehicle Companies (Part 1) — Han Kun Law Offices — September 5, 2023 [^2]: Order No. 521 of the State Council and the Central Military Commission: Regulations on the Administration of Licenses for Weapons and Equipment R&D and Production — Gov.cn (State Council Gazette No. 11, 2008) — March 6, 2008 [^3]: Implementing Measures for Weapons and Equipment R&D and Production Licenses — Gov.cn (Ministry of Industry and Information Technology) — March 21, 2010 [^4]: Release of the 2018 Edition of the Weapons and Equipment R&D and Production License Catalogue — SASTIND (State Administration for Science, Technology and Industry for National Defense) — December 27, 2018 [^5]: Publication of the New Weapons and Equipment R&D and Production License Catalogue — repost of SASTIND announcement (scjg.gov.cn) — September 2015 [^6]: Measures for the Review and Certification of Secrecy Qualifications of Weapons and Equipment R&D and Production Units — Chongqing Municipality (full regulatory text on government site) — February 2021 [^7]: Announcement of the National Administration of State Secrets Protection (Adjustment of Secrecy Qualification Grades, No. 3 of 2021) — Guangdong Provincial Administration of State Secrets — June 30, 2021 [^8]: National Military Standard GJB Certification — Weapons and Equipment Quality Management System GJB 9001C-2017 — certification consultancy explainer (legal basis per Han Kun Law Offices paper) — 2023 [^9]: A Journey to the Stars and the Sea (Part 1: secrecy qualification and foreign investment restrictions) — Han Kun Law Offices — September 5, 2023 [^10]: Key Points on Registration Administration for Equipment Contractor Units — Nanjing Development and Reform Commission (government explainer on military-civil fusion) — February 25, 2025 [^11]: Major Legal Issues in IPOs of Defense-Sector Companies ("two certificates in one" and the "three military certifications") — Sundial Law Firm — 2023 [^12]: Politburo of the CPC Central Committee Meets and Decides to Establish the Central Commission for Integrated Military and Civilian Development — Gov.cn (Xinhua) — January 22, 2017 [^13]: Working Rules for the Joint Review of Weapons and Equipment R&D and Production Licenses and Equipment Contractor Qualifications (Trial) — SASTIND — publication date not stated [^14]: Catch-All Controls in Security Export Control: Japan — JETRO (Japan External Trade Organization) — accessed July 2026 [^15]: Revision of the Catch-All Controls (effective October 9, 2025) — Wakayama University Research Support (explainer of METI materials) — October 9, 2025 [^16]: Revision of the End User List — Ministry of Economy, Trade and Industry (METI) — September 29, 2025 [^17]: Addition of "Military End User" (MEU) List to the Export Administration Regulations and Addition of Entities to the MEU List — Federal Register (BIS) — December 23, 2020 [^18]: Major Legal Issues in IPOs of Defense-Sector Companies (qualification disclosure and disclosure exemptions) — Sundial Law Firm — accessed July 2026 [^19]: A Journey to the Stars and the Sea (Part 1: non-public nature of the license catalogue) — Han Kun Law Offices — September 5, 2023