MOFCOM and Customs Revise Dual-Use Export Classification Review Procedures

China’s Ministry of Commerce (MOFCOM) and General Administration of Customs issued Notice 52 of 2026, effective October 19, replacing Customs Notice 123 of 2025 and revising procedures for questioning whether exports fall within dual-use controls. Exporters receiving a customs query must provide supporting commercial and technical documents within seven working days, including Chinese translations of foreign-language materials. Customs must complete its assessment or refer the goods to MOFCOM within 15 working days of receiving complete materials, and MOFCOM has a further 15-working-day identification period, excluding specified delays and exceptional cases. Questioned goods cannot be released during review, although unrelated goods on the same declaration may be cleared separately with customs approval.