On 17 November, Global Trade Magazine published an article explaining that the new law comes into force on 1 December and creates a comprehensive and unified export control regime that regulates the export of goods, technologies, and services that impact China’s national security. It applies to the export of dual-use items, military products, nuclear materials, and other goods, technologies, services, and items that are related to the protection of national security and performance of international obligations – known as controlled Items. It will apply to the transit, transshipment, through transportation or re-export of controlled items, or the export of controlled items from any bonded areas, export processing zones or other special customs supervision zones or export supervised warehouses, bonded logistics centres or other bonded supervision premises to overseas. It will have extraterritorial effect as well, and hence will impact not only Chinese domestic companies in China but also foreign businesses located outside of China. However, the article says, like other Chinese laws, one notable characteristic of the Export Control Law is the vagueness inherent in the wording, and further definition and explanation is expected in subsequent regulations. The article proposes a number of steps as critical and essential for an effective trade compliance programme under the Export Control Law, and says that they provide a basis and foundation for the compliance programme but do not constitute an exhaustive list.
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