China: Export controls on select aerospace and special organic materials
Implementation of export controls beginning July 1, 2024
Implementation of export controls beginning July 1, 2024
The Ministry of Commerce of China and three other Chinese ministries on May 30, 2024, jointly issued a notice (No.21, 2024), announcing a decision to implement export controls on the following four categories of items and technologies involving aerospace and special organic materials, beginning July 1, 2024:
- Equipment, software, and technology related to the manufacture of aerospace structures and engines
- Equipment, software, and technology related to gas turbine engines/gas turbines manufacturing
- Equipment, software, and technology related to the spacesuit window
- Ultra-high molecular weight polyethylene fiber items
Enterprises involved in the production or export of these controlled items must establish comprehensive internal export control compliance programs to manage compliance risks and ensure adherence to the new regulations.
KPMG observation
The notice includes HS Codes to help enterprises identify controlled items, but these are for reference only. Enterprises must analyze various performance parameters and characteristics to confirm control status. The export of technology and data, as non-physical items, also falls under these controls, highlighting the need for careful management of technical information.
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