China drone export control

China has decided to impose further export controls on equipment, software, and technologies related to the manufacture of aerospace structural components and engines. According to the Ministry of Commerce’s website, the Ministry of Commerce, the General Administration of Customs, and the Equipment Development Department of the Central Military Commission have issued an announcement on the implementation of these new export controls. This move aims to safeguard national security and interests and fulfill international non-proliferation obligations.

The new export controls, effective from July 1, 2024, follow the earlier restrictions imposed on drone exports starting September 1, 2023. (Related news: Announcement on the Temporary Export Control of UAV ) This latest decision significantly broadens the scope of controlled items.

Key Details of the New Export Controls:

  1. Aerospace Structural Components and Engine Manufacturing:
    • Equipment, software, and technologies related to the manufacture of aerospace structural components and engines will now require export licenses.
    • This includes tools, molds, and fixtures specifically designed for superplastic forming/diffusion bonding of titanium, aluminum, and their alloys, software for related research and production, and related technologies and their carriers.
  2. Gas Turbine Engine Manufacturing:
    • Export controls extend to equipment, software, and technologies used in the manufacture of gas turbine engines, including casting equipment for high-temperature alloys, intermediate products for precision casting, and related tools and molds.
  3. Space Suit Face Windows:
    • Specially designed molds for manufacturing space suit face windows, along with associated software and technologies, are also subject to export controls.
  4. Ultra-High Molecular Weight Polyethylene Fiber:
    • Export controls cover ultra-high molecular weight polyethylene fibers with specific properties, as well as soft unidirectional cloth laminates made from these fibers and related technologies.

Application and Compliance: Exporters must follow specific procedures to obtain export licenses, including submitting original contracts, technical descriptions, end-user and end-use certificates, and information on importers and end-users. The Ministry of Commerce, in collaboration with other departments, will review applications and make decisions within the legal timeframe.

Approved exports will receive a dual-use items and technologies export license, and exporters must present this license to customs to complete the necessary procedures. Violations of these controls can result in administrative penalties or criminal charges.

This announcement underscores China’s commitment to tightening control over critical technologies to enhance national security and comply with international obligations.

The specific announcement is as follows:

  1. Items with the following characteristics are prohibited from export without permission: (1) Equipment, software, and technologies related to the manufacture of aerospace structural components and engines:
    • Specially designed tools, molds, and fixtures for superplastic forming/diffusion bonding of titanium, aluminum, and their alloys for the manufacture of the following items:
      • Aerospace structural components
      • Aerospace engines
      • Parts specifically designed for aerospace structural components or engines
    • Software specially designed or modified for the research, production, or use of the above items.
    • Technologies and their carriers used for the research, production, or use of the above items, including design drawings, process specifications, process parameters, processing programs, and simulation data. (2) Equipment, software, and technologies related to the manufacture of gas turbine engines:
    • Directional crystal or single crystal casting equipment for the manufacture of high-temperature alloys needed for gas turbine engine components.
    • Intermediate products for precision casting and tools, molds, and fixtures for the manufacture of these intermediate products.
    • Tools, molds, and fixtures for the solid-state bonding of high-temperature alloys, titanium alloys, or intermetallic compounds for gas turbine engines.
    • Software and technologies for the research, production, or use of the above items. (3) Equipment, software, and technologies related to space suit face windows:
    • Molds specially designed for the manufacture of space suit face windows.
    • Software and technologies for the research, production, or use of the above items. (4) Ultra-high molecular weight polyethylene fiber-related items:
    • Ultra-high molecular weight polyethylene fibers with a breaking strength ≥40cN/dtex, initial modulus ≥1600cN/dtex, and untwisted.
    • Soft unidirectional cloth laminates made from ultra-high molecular weight polyethylene fibers meeting specific performance criteria.
    • Technologies and their carriers for the production of the above items.
  2. Exporters must follow relevant regulations to apply for export licenses through provincial-level commercial authorities by submitting the following documents:
    • Original or consistent copies/scans of export contracts or agreements.
    • Technical descriptions or test reports of the items to be exported.
    • End-user and end-use certificates.
    • Information on importers and end-users.
    • Identification of the legal representative, main management personnel, and handlers.
  3. The Ministry of Commerce will review the export application documents and may collaborate with other departments for examination, making a decision on approval or denial within the legal timeframe.
  4. Approved exports will receive a dual-use items and technologies export license from the Ministry of Commerce.
  5. The application, issuance, special circumstances handling, and document retention of export licenses will follow the relevant provisions of the 2005 Ministry of Commerce and General Administration of Customs Order No. 29.
  6. Exporters must present export licenses to customs, complete customs procedures in accordance with the Customs Law, and accept customs supervision. Customs will process the release based on the export licenses issued by the Ministry of Commerce.
  7. Exporters exporting without permission, exceeding the permitted scope, or engaging in other illegal activities will be subject to administrative penalties by the Ministry of Commerce or customs in accordance with relevant laws and regulations. Criminal responsibility will be pursued for violations constituting crimes.
  8. The export of protective equipment such as bulletproof helmets, vests, inserts, and plates made from ultra-high molecular weight polyethylene fibers, and related materials will follow the provisions of the Regulations on the Administration of Military Product Exports of the People’s Republic of China.
  9. This announcement will be implemented starting July 1, 2024.

Ministry of Commerce, General Administration of Customs, Equipment Development Department of the Central Military Commission

May 30, 2024

(Source: China Ministry of Commerce website)