China expands reporting regime for export control and adds 14 EU entities to control list

China’s Ministry of Commerce (MOFCOM) has intensified export control measures by introducing new export control rules and adding new entities into China’s Export Control Entity List. 

The following is a summary of recent key regulatory developments. 

Enhancement of reporting regime for violations of export control regulations

On 24 June 2026, MOFCOM published Notice No.26 Announcement on Matters Concerning the Further Improvement of the Handling of Reports of Illegal and Non-Compliant Conduct in Relation to Export Controls on Dual-Use Items of Strategic Minerals, which enhances the reporting regime for violations of export control regulations concerning strategic minerals, specifically, rare earth materials. 

This Notice encourages individuals and organisations to report violations of export control regulations, including companies engaged in the following:

• Circumventing licensing requirements for the export of dual-use items related to strategic minerals by means such as modifying products or disassembling them into parts or components;
• Circumventing export control requirements for dual-use items for strategic minerals by routing exports through a third country or region;
• Unlawfully transferring controlled technologies related to strategic minerals overseas through commercial exports, intellectual property licensing, investment activities, exchanges, gifts, exhibitions, displays, inspections, testing, aid, training, joint research and development, employment arrangements or consultancy services;
• Knowingly providing export operators that are conducting unlawful exports of dual-use items related to strategic minerals with agency, freight forwarding, courier, customs clearance, third-party e-commerce platform or financial services;
• Encouraging, facilitating or assisting export operators, importers or end-users in circumventing export control requirements for dual-use items related to strategic minerals or otherwise engaging in unlawful activities; and
• Conducting transactions with importers or end-users included on the control list in violation of the applicable export control regulations.

Legal implications: Entities involved in export activities from China should review their operations and transactions to ensure that they are not engaging in prohibited conduct. They should also implement robust export control compliance programmes and internal controls to mitigate the risk of violations.

Addition of 14 EU entities to China’s Export Control Entity List

On 24 July 2026, MOFCOM announced the addition of 14 EU entities to China’s Export Control Entity List. According to MOFCOM, this measure was introduced in response to the EU’s decision to add 14 Chinese and Hong Kong entities to its sanctions list and constitutes a reciprocal action by China. The 14 designated EU entities include defence companies, advanced technology companies engaged in the semiconductor, photovoltaic, and drone industries, as well as universities and research institutions. 

The designation notice issued by MOFCOM expressly prohibits export operators from exporting dual-use items to these 14 EU entities. Where export is genuinely necessary under special circumstances, the export operator must apply to MOFCOM for approval. 

In addition, overseas organisations and individuals are also prohibited from transferring or supplying dual-use items originating from China to these entities. Any ongoing activities of this nature must cease immediately. If any overseas organisation or individual engages in the prohibited activities, this conduct could constitute a violation of the Export Control Law of the People's Republic of China and the Regulations of the People's Republic of China on the Export Control of Dual-Use Items, and can result in administrative penalties under these regulations, including fines, confiscation of unlawful gains and other enforcement measures. 

Legal implications: Overseas entities should carefully assess whether they have any ongoing transactions or business dealings with any of the 14 listed EU entities. If so, appropriate measures should be considered to mitigate the risk of non-compliance with China’s export control regulations.

Companies operating in or engaging in China should be aware of these changes and evaluate their compliance strategies and market-entry plans. 

For more information on how these changes in China’s export-control policies could impact your China-based or EU-based company, contact your CMS client partner or the CMS experts who contributed to this article: