China is undergoing a significant overhaul of its export control regime with the introduction of a fully redesigned framework structured into six chapters and fifty articles. This new regulatory architecture aims to modernize the rules governing dual-use items, reinforce oversight on sensitive transfers, and provide authorities with greater visibility over exports that may affect national or international security. Exporters are now required to obtain a specific license for each transaction involving sensitive goods, substantiate the intended end-use, and demonstrate that the end-user is not subject to any form of restriction. Chinese authorities are also implementing a stricter monitoring system, with enhanced verification of end-use certificates and increased scrutiny of entities considered to be aligned with sensitive countries.
A particularly notable aspect of this reform is the clear expansion of its scope beyond Chinese companies to include foreign actors involved in logistics chains, transshipment operations, or any transaction maintaining a sufficient nexus with China. Exporters, forwarders and logistics providers must now report suspicious behaviour or potential violations, reinforcing the idea of shared responsibility across the export ecosystem. By consolidating previous frameworks while imposing stricter obligations, Beijing sends a strong signal: export controls are becoming a central pillar of both its security strategy and economic governance. For companies, the question is no longer whether these rules will have an impact, but whether they are prepared to adapt to a tightening regulatory environment that now extends well beyond China’s borders.