Questions and answers about China

  • China and Commercial Items 7A994 and 7D994

    Question: Good morning, members I recently started working for a new aerospace company that mainly does commercial items that fall under 7A994 and 7D994.  The only control for those items is AT but some of our sales are to Chinese and Venezuelan Civilians (no military).   Can we still use NLR as both countries are not […]

  • 744.23 Semiconductor manufacturing equipment & FDP Rules

    Question: I have a foreign made item that I have determined is not subject to the EAR based on FDP rules. The item is EAR99 and all items in the bill of materials are EAR99 so therefore there is no controlled US content. This item is used for gas and chemical delivery systems incorporated into […]

  • EAR 15 CFR 744.23(a)(1)(v)

    Question: Greetings! I work for a company that manufactures EAR99 items that contribute to “The “development” or “production” in the PRC or Macau of any “parts,” “components,” or “equipment” specified under ECCN 3B001, 3B002, 3B090, 3B611, 3B991, or 3B992.”. Since the new regulations of 744.23 in Oct of 2022 I have received mixed responses from […]

  • Temporary Import

    Question: I had a discussion with a customer that is looking to import some material from China to Mexico but would like to take possession of the material at a US port and then import to Mexico.   We will drop ship the product from China.  The customer claims that since it is a temporary transaction, […]

  • UFLPA ACE Enhancement Region Alert Information Notice for Trade

    Question: UFLPA ACE Enhancement Region Alert Information Notice for Trade ( In the publication from CBP of Nov 2, (link above) listed what will change for trade users, wondering if the trade is interpreting the below item in italics / bold, meaning any time a shipment of CN origin, it will be required to provide […]

  • UFLPA compliance and supply chain due diligence

    Question: We buy product DDP from a Chinese vendor.  We do not source the fabric or any of the buttons etc.  We simply buy the garment that the vendor designs.  We learned recently during a supply chain review that the source of the fabric and yarn is Xinjiang, China which is subject to the UFLPA […]

  • Export from China

    QUESTION: A facility in Europe wants to import parts from China, the supplier says it is not able or doesn’t have any certifications to export out of China. How can we get export documents in this case? Are there any exports restricted by China? If so, where would I find a list of what those […]

  • Shipments to China and weight info required on documents

    QUESTION: I am trying to find regulations which clearly identify what is required to be on invoices going into China and Brazil as it relates to weight.  I believe that net and gross weight need to appear but I am not sure of the following: Gross and net of the item or of the packaging? […]


    QUESTION: Does anyone have the most recent China MOFCOM dual-use import and export list that is subject to licensing? Believe it was announcement 68 in end of 2019 and published in 2020? I was having difficulty finding it on MOFCOM website. =========== Answer: Received the Chinese version from a colleague in Shanghai.  Used Microsoft Translator […]


    QUESTION: One of our Chinese partners wants us to ship to them DDP.  We do not have an entity in China so cannot be the IOR. Does China have a Non Resident Importer program (NRI) ?  If there is an NRI program, I am sure there is some sort of foreign entity registration process.  Can […]

  • MOFCOM Validity Period

    QUESTION: I work for a company that frequently exports controlled parts to China and has to obtain a MOFCOM certificate due to the value. We’ve never had an issue with these, but we’ve noticed they do state on the certificate they are valid for 6 months. We typically have larger bulk licenses that will account […]