2026 Machine Tool Export New Regulations: Dual-Use Item Determination Criteria and License Application Procedures

Currently, when enterprises export or procure machine tools such as lathes, milling machines and grinding machines manufactured in China, they must first verify whether the relevant items are subject to dual-use item export control. This article aims to systematically explain the determination criteria for machine tools classified as dual-use items, and to detail the application procedures for export licenses, so as to help enterprises complete export business in a compliant and efficient manner.

I. Determination Criteria for Machine Tools as Dual-Use Items
1. Verifying Technical Indicators against the Control List: Key Parameter Thresholds

To determine whether CNC lathes, machining centers and turning centers are classified as dual-use items, a strict item-by-item comparison must be made against the technical indicators listed in the Catalogue of the People's Republic of China on Export Control of Dual-Use Items. The core determination parameters are as follows:

a. Lathes possessing both of the following characteristics: 1. Lathes capable of machining workpieces with a diameter greater than 35 mm; 2. According to ISO 230-2:1988 or equivalent national standards, “positioning accuracy” achievable along any linear axis to less than 6 µm (total “positioning accuracy”) after all compensations have been applied.
Note: Item 2B201.a does not control bar lathes that only process through-feed bar stock, where the maximum bar diameter is less than or equal to 42 mm and there is no capability for mounting chucks. These lathes may perform drilling and milling operations on parts less than 42 mm in diameter.

b. Milling machines possessing any of the following characteristics:
Note: Item 2B201.b does not control milling machines possessing both of the following characteristics: 1. X-axis travel greater than 2 m; 2. According to ISO 230-2:1988 or equivalent national standards, total “positioning accuracy” along the X-axis greater than 30 µm.

3. Note on Common Misconceptions

c. Grinding machines possessing any of the following characteristics:

1. According to ISO 230-2:1988 or equivalent national standards, “positioning accuracy” achievable along any linear axis to less than 6 µm (total “positioning accuracy”) after all compensations have been applied;

2. Having two or more contouring rotary axes;

3. Having five or more axes which can be coordinated simultaneously for “contouring control”.

If the goods have the same or similar names as controlled items but the technical indicators do not meet the requirements described in the Control List, an export license is generally not required. However, according to Article 12 of the Export Control Law, if the exporter knows or should know that the items intended for export pose a risk of harming national security and interests, or being used for weapons of mass destruction and their means of delivery, or for terrorist purposes, a license must be applied for.

II. License Application Procedures
Once a machine tool is determined to be a controlled item, a Dual-Use Items Export License must be obtained. The current application process has been fully digitalized. The specific procedures are as follows:

Step 1: System Login and Form Filling

Access the “Dual-Use Items Export Control Management System” through the MOFCOM Business System Unified Platform (https://ecomp.mofcom.gov.cn) and fill in the Application Form for Dual-Use Items and Technologies Export License online. The following key information must be truthfully entered:

Exporter, Importer, End-User: The exporter information will be automatically populated after system registration. The importer and end-user must provide the standard full foreign name or standard full Chinese name. The Chinese name should be the standard translated name.

Importing Country/Region and Final Destination Country/Region: The importing country refers to the country or region where the importer is located as specified in the foreign trade contract; the final destination country refers to the country or region where the goods are actually shipped to and used. If these two are different, supplementary materials must be provided explaining the reason and the actual transportation route.

Contract Information: The contract number, contract signing date (if the signing dates of the two parties differ, the last signing date shall prevail), trade method, payment method, currency, etc., must all be completely consistent with the uploaded contract content.

Item Information: Select the goods name and control code by referring to the Control List. Not all controlled items have pre-set options for Customs Commodity Codes (HS Codes). If there is no corresponding code in the system, it should be truthfully filled in independently. The specifications and grade columns should include the specific model, specifications, grade, and other parameters of the item intended for export.

Commodity Technical Description: This is the key to determining whether the item falls under control. The actual situation of the corresponding indicators of the item intended for export must be clearly filled in, strictly compared against the specific item description in the Control List, to ensure a clear judgment can be made that the export commodity falls within the scope of control. Technical information of the item beyond the key indicators may be appended on separate sheets.

Commodity End-Use: The description should be specific, accurate, and targeted, rather than a general statement about the field of use, and should be consistent with the end-use description in the End-User and End-Use Certificate document.

Step 2: Submitting Core Application Materials

Once submitted online, the application cannot be modified. Please ensure the information is accurate. The following paper materials must be submitted (all stamped with the enterprise seal, and filled in Chinese unless otherwise specified):

1. Printout of the application form (1 original, in duplicate sheets)

2. One original copy and one Chinese translation of the End-User and End-Use Certificate (the translation must be stamped with the enterprise seal; the format can be downloaded from the website of the Security and Control Bureau)

3. One copy of the contract

4. One technical description of the export items for which the license is applied

5. Proof of identity of the legal representative (copy of the legal person certificate and identity card) and one specimen signature; if someone else is authorized to sign, provide the original authorization letter (including the authorized person’s name, position, specimen signature, scope of authorization, and validity period). The original is submitted for filing upon the first application; stamped copies may be submitted subsequently

6. Proof of identity of the principal responsible person and the handling agent of the enterprise (employment certificate and copy of identity card) – one copy each

7. One company profile issued by the end-user (either in Chinese or English; if in English, a Chinese translation stamped by the exporter must be attached; including business status, main products, website, person-in-charge, etc.), it is advisable to attach the enterprise brochure

8. Other documents required by MOFCOM

Step 3: Material Submission and Review

The original End-User and End-Use Certificate and the application form stamped with the enterprise seal and paging seal must be submitted to the provincial competent commerce department where the enterprise is located. The provincial competent commerce department will forward applications that meet basic requirements to MOFCOM. After acceptance by MOFCOM, the review will be conducted by MOFCOM independently or jointly with relevant state departments according to the law. The review period is 45 working days from the date of acceptance. If materials need to be returned for supplementation, the review time is calculated from the date MOFCOM receives complete materials that meet the requirements. The time required for legally mandated identification, solicitation of expert opinions, or on-site verification is not counted within the review period. For exports that have a significant impact on national security and interests, approval must be submitted to the State Council or the State Council and the Central Military Commission, and the above review time limit does not apply.

Step 4: License Collection and Customs Declaration

After approval, the enterprise can download the electronic approval notice from the system, and with this notice, collect the Dual-Use Items Export License from the license issuing system of the provincial competent commerce department. The license is generally valid for 6 months. If the license validity period spans across the year and expires after March 31 of the following year, it can be exchanged for a license with the actual validity period at the local license-issuing agency before March 31. Customs will process export release procedures based on the electronic license data. Licenses are operated on a “one license per shipment” basis. If partial shipments are required, one application form can be used to apply for multiple licenses, with a maximum of 12.

(This article is compiled based on publicly available official documents such as the Instructions for Filling in the Application for Dual-Use Items Export License and the FAQ on Dual-Use Items Export License Applications published on the official website of MOFCOM, and is for the reference of relevant export enterprises. Specific implementation shall be subject to the latest interpretation by the competent authorities. For consultation on machine tool export compliance determination or procurement, please contact Lichi Machinery.)