Navigating China’s Dual-Use Export Licensing Regime

Key Takeaways

• Amid industry frustration over slow approvals of dual-use items like rare earth magnets, MOFCOM is piloting general licenses and license exceptions.
• Regulators see this as an adaptation period for themselves and for businesses to become familiar with products, end uses, and application processes.
• Approvals largely depend on how compliant the Chinese supplier is, and on having clear, end-to-end traceability of the goods.