1. What "dual-use items" are

Direct answer: dual-use items are goods, technology and services with both civilian and military uses, or the potential to contribute to military capability. The current list, control code and actual technical parameters determine classification.

They often look like ordinary industrial products — special-alloy tubing, machine tools, chemicals, graphite materials, drone components or encryption software. Companies need a traceable classification process rather than relying on commercial descriptions or intuition.

2. The framework: one law, one regulation, and the lists

  • The Export Control Law (2020) is the basic statute. It establishes control lists, licensing, end-user and end-use management, and extraterritorial application.
  • The Regulations on Export Control of Dual-Use Items (published 2024) is the core administrative regulation. It replaced several older special regulations and measures. These covered nuclear, biological, missile-related and certain chemical items. Manuals that still present them as current core authority need review.
  • Control lists and announcements change over time. A later instrument can suspend or amend an earlier one. For example, Announcement 70 suspends six 2025 announcements until 10 November 2026. Checking current status is as important as finding the original publication.

3. Four things a company must do

  1. Classify products against the current control lists to judge whether an item is controlled. When unsure, you may seek a classification opinion from the authorities.
  2. Apply for licences before exporting controlled items — "licence before goods".
  3. Screen transactions. Check the customer, end use and shipping route. Review each shipment and retain the result. Catch-all controls may still apply to an unlisted item. Stop if known facts point to weapons of mass destruction or a similar prohibited purpose.
  4. Keep records: file review records, documents and statements so they are traceable.

4. The order of magnitude of a violation

The Export Control Law sets out several consequences for unlicensed exports and similar violations. Authorities may order the conduct to stop. They may confiscate illegal gains and impose fines based on illegal turnover. Serious cases can lead to loss of business qualifications. Conduct that constitutes a crime can create criminal liability.

A violation record can also enter the credit system. That record may affect later licence applications and customs credit ratings. The resulting burden can raise the cost of future transactions.

For exact penalty provisions and amounts, rely on the current official legal text (see sources below).

5. Where to start

If your company lacks a systematic export-control process, do not try to perfect it in one step. Begin with three controls:

  1. Compare your product list with the current control lists.
  2. Add a minimum review checklist to every export.
  3. Give one responsible person authority to stop a high-risk order.

Then build a complete Internal Compliance Program around the nine elements. The next article explains that framework.