On December 1, 2024, China’s new Export Control Regulations on Civil-Military Dual-Use Items took effect. The regulations, issued by MOFCOM and the Ministry of Justice, updated the framework for controlling items with both civilian and military applications.
As analyzed by Pillsbury Law, the anticipated updated Dual-Use Items Control List was expected to include quantum computing, AI, encryption, semiconductors, drones, and biotechnology. The regulations applied “deemed export” provisions to the transfer of dual-use items to foreign nationals within China, and extended controls to dual-use items manufactured outside China using Chinese-origin technologies.
MOFCOM and MOJ were updating the Dual-Use Items Control List at the time the regulations took effect. The regulations represented China’s continued development of its own export control framework covering quantum technologies, separate from and partly in response to expanding U.S. export controls on quantum items.