Businesses involved in international trade should take note of significant regulatory changes coming in 2026. China's Ministry of Commerce and the General Administration of Customs have jointly issued Announcement No. 91 of 2025, introducing updates to the Catalog of Dual-Use Items and Technologies Subject to Import/Export License Administration for the coming year.
The revised catalog, which takes effect January 1, 2026, will serve as the primary compliance standard for companies engaged in cross-border transactions of controlled goods. The update reflects adjustments made to align with China's Export Control Law and incorporates changes from the latest edition of the Import and Export Tariff Schedule of the People's Republic of China .
Key Changes and Compliance Requirements
Among the notable provisions, importers of radioactive isotopes must pay particular attention to new documentation requirements. These businesses must first obtain approval from the Ministry of Ecology and Environment before applying for import licenses through the Ministry of Commerce's Quota and License Administrative Bureau.
The updated regulations will replace the previous framework established under Announcement No. 67 of 2024. Industry analysts suggest the changes may affect compliance costs and operational efficiency for companies trading in sensitive technologies and materials.
Implementation Timeline
With the new rules set to take effect in approximately eighteen months, trade compliance experts recommend businesses begin reviewing their internal processes now. Early adaptation to the revised standards may help avoid potential supply chain disruptions when the changes become mandatory.
The announcement marks China's continued efforts to refine its export control system while maintaining alignment with international nonproliferation standards. Companies operating in sectors affected by dual-use controls should consult with legal experts to ensure full compliance before the 2026 implementation date.