On 19 October 2026, the Ministry of Commerce and the General Administration of Customs issued Announcement No. 52 of 2026. It took effect the day it was published and replaced Customs Announcement No. 123 of 2025. It governs one stretch of the export process: from the moment customs questions whether a shipment is a controlled dual-use item to the moment the goods are cleared or handled otherwise. The hardest edge for exporters is a deadline — seven working days from receiving the query notice to hand over four sets of documents. Below is the sequence, both clocks, and the three points most companies miss.

AC Core Highlights

1. What Announcement No. 52 Changes

Two things. The response becomes time-bound: a fixed 7 working days to submit, a fixed 15 working days for customs to decide. And the process becomes documented: customs must issue a Dual-Use Item Export Control Customs Query Notice when it raises the question, and a Dual-Use Item Export Control Customs Query Result Notice when it finishes. Every stage now has an owner, a clock and a piece of paper attached to it.

2. When Customs Will Question Your Shipment

You declare goods for export without presenting an export licence issued by MOFCOM, and customs has evidence suggesting the goods may fall within dual-use export controls. Customs then raises the question with you and issues the query notice. Two details matter: the trigger is evidence, and the party being questioned is the exporter named on the declaration — not the overseas buyer.

3. The Four Sets of Documents — Within 7 Working Days

The clock runs from the day you receive the notice. Every document must carry the company seal; anything in a foreign language needs a Chinese translation attached.

① Shipping documents — the customs declaration, the export contract, the invoice, and transport documents showing where the goods are going.

② Written explanation — the goods’ performance specifications and principal uses, plus the legal basis and factual grounds for saying they fall outside export controls. This is where most files are thinnest: "it is not controlled" on its own does not hold; the specifications and the stated use have to carry the conclusion.

③ Technical data — material that proves what the goods actually are. If you have test or inspection reports, attach them.

④ Anything else customs requires.

4. What Happens Next — Two 15-Working-Day Clocks

Customs assesses what you submit and, where needed, asks MOFCOM to organise expert identification, which may include sending the goods for testing. Both clocks start from receipt of the complete file, not from the day of the notice:

· Customs: 15 working days from receiving all documents to complete its assessment, or to refer the matter to MOFCOM;

· MOFCOM: 15 working days from receiving the complete referral to issue its identification conclusion.

There are three outcomes, and each is confirmed in writing: not dual-use → clearance continues; dual-use → handled under the applicable rules; other circumstances → handled as required. Time spent submitting or supplementing documents, and time spent on testing, does not count toward either clock. Major or difficult cases are not bound by these limits.

5. Three Points Companies Miss

· Nothing moves while this runs. Goods are not released during the query and identification period. Unrelated goods under the same declaration can be split out and cleared separately — but only after customs assesses and agrees.

· Other channels are covered. Exports of dual-use items through cross-border e-commerce, goods carried by travellers, mail and express shipments follow the same announcement.

· Silence is not an option. Materials must be provided truthfully and supplemented as required, with reliable content and data. No refusal, obstruction, concealment or false statements.

6. What to Prepare Before the Notice Arrives

Seven working days is short and the file is document-heavy, so the work has to start earlier:

· Keep a standing pack per product line: declaration data, contract template, invoice, transport documents, specification sheet, end-use statement, test reports;

· Decide who signs and who seals in advance — every document needs the seal, and foreign-language papers need a translation;

· Draft the written explanation alongside the technical file, not after it;

· If you ship by e-commerce, mail or express, confirm the same rules reach you.

AC has worked with foreign investors in China since 2003, and import and export agency is part of our regular work. If a query notice arrives — or you want to know in advance whether your product sits close to the control list — send us the product and its specifications, and we will go through the file with you to see what is missing.

Disclaimer: This article is interpreted by AC Consulting for reference only. It does not constitute tax, legal or compliance advice. All implementation standards shall be subject to the latest official documents released by competent authorities.