What Is Dual-Use Export Control?
China rolled out new export controls on a long list of drone-related equipment for both military and civilian use, with the Ministry of Commerce (‘MOFCOM’) saying items with certain characteristics ‘shall not be exported without permission’ and violators will face punishment.
Exporters shall go through the export licensing procedures in accordance with relevant regulations, apply to the Ministry of Commerce through the provincial commerce authorities, fill in the export application form for dual-use items and technologies’ and submit relevant documents, the directive said.
It also cautioned businesses: ‘For all unmanned aerial vehicles that are not included in the export control list or not subject to temporary control, the export operator shall not export them if it knows or should know that the export will be used for the proliferation of weapons of mass destruction, terrorist activities or military purposes. Violators shall be punished in accordance with Article 34 of the Export Control Law of the People’s Republic of China.
Dual-Use UAV Items Export Control Catalog
| HS Code | Category | Description |
|---|---|---|
| 8806229010 | Drone | Other unmanned aerial vehicles with a maximum take-off weight of 250g and less than 7kg that are only flown by remote control (dual-use items and technologies subject to export control) |
| 8806239010 | Drone | Other unmanned aerial vehicles with a maximum take-off weight of 7 kg or less and ≤ 25 kg that are flown only by remote control (dual-use items and technologies subject to export control) |
| 8806249010 | Drone | Other unmanned aerial vehicles with a maximum take-off weight of 25 kg or less and 150 kg that are flown only by remote control |
| 8806299010 | Drone | Other unmanned aerial vehicles with a maximum take-off weight > 150 kg that are flown only by remote control |
| 8806929010 | Drone | Other unmanned aerial vehicles with a maximum take-off weight of 250g or less and a maximum take-off weight of 7kg or less |
| 8806939010 | Drone | Other unmanned aerial vehicles with a maximum take-off weight of 7 kg or less and a maximum take-off weight of 25 kg or less |
| 8806949010 | Drone | Other unmanned aerial vehicles with a maximum take-off weight of 25 kg or less and a maximum take-off weight of 150 kg or less |
| 8806990010 | Drone | Other unmanned aerial vehicles with a maximum take-off weight of more than 150 kg |
| HS Code | Category | Description | Specification |
|---|---|---|---|
| 8525891110 | Thermal imaging camera | Thermal imaging TV camera for drones under dual-use item control | 1. Wavelength range: 780~30000 nm 2. Instantaneous field of view < 2.5 mrad |
| 8525892110 | Thermal imaging camera | Thermal imaging digital camera for drones under dual-use item control | |
| 8525893110 | Thermal imaging camera | Thermal imaging camera for drones under dual-use item control |
| HS Code | Category | Description | Specification |
|---|---|---|---|
| 8526109011 | Synthetic Aperture Radar | Airborne radar for drones under dual-use item control | The effective range is greater than 5 km and has any of the following characteristics:
|
| 9013200093 | Target designation laser | Dual-use items controlled: lasers for drones and high-power lasers for civil anti-drone systems | It can work stably in an environment above 55°C and has all the following characteristics:
|
| HS Code | Category | Description | Specification |
|---|---|---|---|
| 8517629910 | Radio communication module | Dual-use items controlled wireless communication equipment with both sending and receiving functions for drones | Possess any of the characteristics:
|
| 8517691002 | Radio communication module | Wireless communication transmitting or receiving equipment for drones under dual-use item control | |
| 8526920010 | Radio communication module | Dual-use items controlled by radio remote control equipment for unmanned aerial vehicles |
| HS Code | Category | Description |
|---|---|---|
| 8543709960 | Electronic jamming equipment for civil anti-UAV systems under dual-use item control | Anti-UAV electronic jamming equipment with a jamming range greater than 5 km |
| 9013200093 | Lasers for drones and high-power lasers for civil anti-drone systems under dual-use item control | High-power lasers with an output power greater than 1.5 kW, specifically for counter-UAS systems |
| HS Code | Category | Description |
|---|---|---|
| 9014209013 | Gyro-stabilized platform | Gyro-stabilized platform |
| 9014201010 | Autopilot for unmanned aerial vehicles | Autopilot for unmanned aerial vehicles |
| 9014800010 | Accelerometer with proportional error less than 0.25% | Accelerometer with proportional error less than 0.25% |
| 9014209015 | Gyroscope | Gyroscopes with a rated “drift rate” of less than 0.5 º/h. |
| 9014209011 | Aviation Inertial Navigation Unit | Astronomical gyrocompass and other devices that use celestial bodies or artificial satellites for navigation. |
| 9014209012 | Aviation Inertial Navigation Unit | Astronomical gyrocompass and other devices that use celestial bodies or artificial satellites for navigation. |
| 9014209016 | Specially designed navigation information processor | Specially designed navigation information processor. |
| 9014800020 | Altimeter/Navigation Instrument | Altimeter for target detection. |
| 9014209014 | Inertial Measurement Equipment | Inertial measurement equipment that with all of the following features:
|
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