What changed and where it applies

China's Ministry of Commerce and General Administration of Customs issued Announcement No. 52 of 2026 on 19 October 2026, and it took effect on the date of publication. It replaces General Administration of Customs Announcement No. 123 of 2025. The notice sets out a procedure for a China export customs inquiry when Customs has evidence that goods may fall within dual-use export controls and no relevant export licence was presented with the declaration.

This is a China export-control and customs procedure, not an import permit or product-certification rule for Taiwan, Indonesia or any African country. It is not a finding that every questioned item is controlled. If the inquiry begins, the China export goods concerned are not released while the inquiry or identification is pending. Buyers should confirm current treatment with the Chinese exporter and, where needed, a qualified export-control adviser.

The exporter's response file and clock

Under the notice, the exporter must provide requested materials within seven working days after receiving the customs inquiry notice. The listed file includes the export declaration, sales contract, invoice and transport documents showing the cargo's route; an explanation of performance indicators, main use and the facts and legal basis for the exporter's position; and technical material that supports the item's characteristics, including test or inspection reports if available. Customs may ask for other material.

The materials must carry the company seal. Documents in a foreign language must also include a Chinese translation. After all required material is received, Customs has 15 working days to decide the inquiry or refer the matter to the Ministry of Commerce for identification. The Ministry has 15 working days after receiving a complete identification file. Exporter supplements and testing time do not count toward those periods, and major or difficult cases are not bound by the stated limit, so the periods are not a guaranteed cargo-release date.

How a buyer can prevent avoidable gaps

Before confirming the order, ask the Chinese supplier for the exact manufacturer, model, configuration and technical datasheet—not just a marketing name. Share accurate end-user, intended-use, final-destination and onward-transfer information with the exporter. Ask which specifications or test records would help distinguish the item from controlled descriptions, and make sure the same model and revision appear across the purchase order, invoice and technical file.

The exporter is the party addressed by the customs notice and is responsible for its export declaration and response. A foreign buyer can supply accurate commercial, use and recipient information promptly, but should not draft a false classification statement or promise that the goods are outside control. Any conclusion about control status or licence requirements belongs with the exporter and competent authorities or advisers. Destination-country import approvals and duties remain a separate workstream.

Build a practical pre-shipment decision gate

If an inquiry notice arrives, ask the exporter to identify the response owner, notice-receipt date, seven-working-day deadline, missing documents and translation or company-seal requirements. Keep the buyer's response channel ready for end-user or use information, but send only accurate and authorized data. Ask the forwarder not to treat an estimated sailing date as confirmed while the queried cargo is held.

The notice says unrelated goods on the same declaration may be handled separately only if the exporter requests a split and Customs assesses and approves it. Do not assume other cartons can automatically ship. Record the written status, responsible party and next update date, then recheck the actual export-release evidence before confirming onward transport.

Your next-order checklist

  • Record Announcement No. 52's publication and effective date as 19 October 2026; it replaces GAC Announcement No. 123 of 2025.
  • Before order confirmation, collect exact manufacturer, model, configuration, technical specifications, end user, intended use and destination.
  • Keep the export declaration, contract, invoice, route documents and item-characteristic evidence consistent for the exporter.
  • If Customs issues an inquiry, help the exporter meet its seven-working-day response deadline and supply accurate buyer-side evidence promptly.
  • Do not treat the 15-working-day review periods as a guaranteed release date; supplements, tests and exceptional cases affect timing.
  • Keep China export-control handling separate from the buyer's destination import permits, taxes and local delivery checks.

Sources & reference dates

  1. Ministry of Commerce and General Administration of Customs Announcement No. 52 of 2026 on optimizing customs inquiries and identification of dual-use itemsSource published: 2026-10-19Effective: 2026-10-19
  2. General Administration of Customs Announcement No. 123 of 2025 on customs inquiries for export-controlled dual-use items (superseded)Source published: 2025-06-16

Prepared by the Yifeng Sourcing editorial team with AI assistance from the primary sources listed below. Source dates are recorded; destination-specific requirements should be reconfirmed before acting. This is not legal or tax advice.