1. What dual-use means
Items with both civilian and military applications.
The control regime covers goods, technologies and software.
2. The Chinese regime
Consolidated export control.
A catalogue of controlled items.
Licensing for listed items and destinations.
3. What a licence application requires
End-user and end-use statements
Signed by the consignee.
Technical specifications
Sufficient to match the item to the catalogue entry.
Route and consignee details
Including intermediate consignees where any.
4. The scrutiny that makes it slow
The authority may consult other agencies.
It may query the end user’s identity or business.
It may require additional documentation.
5. The catch-all principle
Items outside the catalogue may still require a licence where the exporter knows or suspects a military end use.
That places a judgement obligation on the exporter.
6. The scenario
An exporter of industrial sensors shipped to a distributor who resold to a prohibited end user.
The sensors were not listed.
The catch-all provision applied, and the exporter’s internal records could not show what it knew.
7. What to build
End-user due diligence for every consignee.
A written screening record.
8. Closing view
Dual-use control is not only a catalogue lookup.
The catalogue is the floor.
*This article is based on China’s export control law and dual-use item export licensing rules.*