New Regulations on Dual-Use Items Bolster China’s Export Control Regime

Key Takeaways

• China has released new export control regulations on dual-use exports, granting MOFCOM increased visibility and enforcement capability over high-tech supply chains.
• The new rules also apply to foreign-origin items containing controlled components from China, which may present significant new compliance obligations.
• Whether the rules expand into previously uncontrolled sectors will depend on regulators’ perceptions of dual-use technology development and geopolitical circumstances.