On December 31, 2025, China's Ministry of Commerce (MOFCOM) and the General Administration of Customs (GACC) jointly issued Announcement No. 91 of 2025, releasing the 2026 Catalogue of Dual-Use Items and Technologies Subject to Import and Export Licensing. The catalogue took effect on January 1, 2026, replacing the 2025 version and the earlier catalogue issued under MOFCOM & GACC Announcement No. 67 of 2024.

For exporters, the practical rule is simple but unforgiving: if an item appears in the catalogue, its import or export requires a dual-use item and technology license issued by MOFCOM or an authorized local counterpart, and customs will release the goods only after verifying a valid license. No license, no clearance.

What Changed in the 2026 Edition

The catalogue was adjusted in line with China's Export Control Law, the Regulations on the Export Control of Dual-Use Items, the licensing administration measures, the Dual-Use Items Export Control List, and the 2026 Customs Tariff. Two points stand out:

  • A shift in legal anchor. The 2025 edition stated that, in case of discrepancy, the Joint Announcement No. 51 of 2024 would take precedence. The 2026 edition replaces that specific reference with a broader pointer to the standalone "PRC Dual-Use Items Export Control List" and related announcements. This signals that the catalogue is now aligned with a standalone control-list instrument rather than a single inter-agency announcement — a more durable legal footing that exporters should expect to be updated independently.
  • Classification rests on item descriptions, not HS codes alone. Especially for chemicals, regulated industrial inputs, and machinery, the licensing determination often turns on detailed product descriptions and technical parameters rather than the HS code by itself. A product that looks like an ordinary export by tariff code can still be a controlled dual-use item by specification.

The Broader Export-Control Backdrop

The catalogue does not operate in isolation. Across late 2025 and into 2026, China issued a series of targeted export-control measures — including end-use and end-user standards applied to specific destinations and tightened treatment of certain advanced minerals, rare-earth-related items, and sensitive technologies. Some controls have been paused pending bilateral negotiation, while others remain active. The net effect is a landscape where the same component can move freely one quarter and require a license the next.

Two compliance habits follow directly:

  • Map your bill of materials. Identify every component and input that could fall within the 2026 catalogue, particularly minerals, magnets, high-precision sensors, specialized alloys, carbon fibers, and certain software. The control may attach to an input deep in the product rather than the finished good.
  • Strengthen end-user documentation. Where controls apply an end-use or end-user test, scrutiny of end-user certificates is rising. Clear, verifiable documentation distinguishing civilian use from controlled applications reduces the risk of a held or rejected declaration.

Why Timing Matters

Because these catalogues are updated annually and become operational immediately at the start of the year, the early weeks of any year carry elevated risk of clearance delays for items whose status has changed. A license application under the dual-use regime can take significant lead time, so discovering a licensing requirement at the port is the worst place to discover it. Exporters of chemicals, industrial machinery, electronics, and advanced materials should re-run their classifications against the 2026 catalogue rather than relying on last year's determination.

How Zhongshen Can Help

As a licensed customs and export-agency provider, Zhongshen can screen your products against the 2026 dual-use catalogue, flag where a MOFCOM license is required before clearance, advise on end-user documentation, and coordinate the license application so your shipment schedule isn't derailed at the border. Contact our customs desk for a dual-use classification check on your export lines.