China Issues Guidance on Customs Inquiries for Dual-Use Item Exports Under Bulletin 123

GAC issued Bulletin 123 on 16 June 2025 for guidance on dual-use item exports.
Exporters must present a dual-use item export license when declaring goods.
If evidence suggests goods are dual-use, customs will suspend shipment and issue an inquiry notice.
Exporters have seven working days to submit required documents for review.
Required documents include customs declaration forms, export agreements, explanation letters, and technical documents.
Chinese translations are needed for documents in foreign languages.
Customs will determine if goods need an export license and may refer cases to other authorities.
If a license is needed, goods are detained and further inspections may occur.
Violations can lead to fines and suspension of business operations.
Goods remain detained throughout the inquiry process.
Exporters face challenges like unclear timelines, operational disruptions, and increased compliance burdens.
Exporters should prepare to manage compliance and potential disruptions.

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.