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Dual-Use Export Licensing: What an Application Needs

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.*

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