trade, great attention has always been paid to the export control of technology and products, especially for high - tech products that may be dual - use. On July 31, 2023, the Ministry of Commerce and relevant departments jointly issued the Announcement on the Implementation of Export Control on UAV - related Items and the Announcement on the Temporary Export Control of Some UAVs. New control measures for UAV exports were officially implemented from September 1, 2023. It should be noted that this is not the first time China has imposed controls on UAV exports. Relevant announcements were issued in 2015, but this announcement is more detailed and complete.foreign tradeRefined and Expanded Controlled Items:
The new announcement not only refined and clarified the content of the 2015 announcement but also expanded the scope of controlled items. For example, the description of the relevant equipment and components of specific UAVs in the 2015 announcement was relatively general, while this announcement clearly stipulates the relevant technical indicators.Emphasis on Export Control of Non - listed Items:
Based on the Export Control Law, Announcement No. 28 clearly states that even if certain goods are not clearly listed in the control list, if the exporting enterprise knows or should know that these goods will be used for specific purposes such as military or terrorist activities, they are still subject to export control.First Implementation of Temporary Control:
First implementation of temporary control:Announcement No. 28 is the first temporary control measure adopted after the implementation of the Export Control Law. It clarifies its implementation period and is consistent with the relevant provisions of the Export Control Law.
Clarification of the export license procedure:There are differences in the export license procedures between the new announcement and the 2015 announcement. When applying for an export license, relevant enterprises need to compare the technical indicators of their products with those of each announcement to determine the applicable announcement and the relevant export license application procedures.
Facing the new regulations on export control, relevant enterprises first need to compare the technical indicators of each announcement, carefully sort out their export products, and judge whether they fall within the scope of control. If so, they should apply for an export license in accordance with the relevant procedures. At the same time, they should also pay attention to the interpretations and guidelines of regulatory authorities to ensure compliant operations.
Considering that after the release of the new export control measures, enterprises have a relatively short response time, enterprises should accelerate the establishment of an internal export control compliance mechanism. Pre - organize product, importer and end - user information to quickly respond to possible changes in export control.
? 2025. All Rights Reserved. 滬ICP備2023007705號-2 PSB Record: Shanghai No.31011502009912