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Exporting electrical and electronic products from China

Electronics are declared to customs at least 24 hours before loading. A licence from MOFCOM is needed where an item is a listed dual-use item or carries a known risk, though encryption in mass-market consumer products is not controlled. GACC spot-checks low-voltage electrical apparatus among exports, and dangerous goods need appraised packaging.

Updated · Each section links to the official source it comes from

Export controls
MOFCOM, under the Export Control Law
Mass-market encryption
Not subject to export control
Spot checks from 1 June 2026
Low-voltage electrical apparatus, among others
Dangerous goods
Packaging appraised before export
Declaration
At least 24 hours before loading

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Is the product, or a part of it, on the dual-use export control list? Read more
  2. 2Does it use cryptography, and is it a mass-market consumer product? Read more
  3. 3Is it spot-checked by GACC, or shipped as dangerous goods needing appraised packaging? Read more
  4. 4Are the documents and any licence ready 24 hours before loading? Read more
  5. 5Is a certificate of origin needed? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Export controls

Licensing for dual-use items and other controlled goods, technologies and services.

  • The Export Control Law (出口管制法) covers dual-use items, military products, nuclear items and other items tied to national security, including related technical data (Article 2). It took effect on 1 December 2020.
  • Items on a control list or under temporary control need a licence; other goods need one where the exporter knows or should know, or is told, of a risk to national security or of use for weapons of mass destruction or terrorism (Article 12).
  • An exporter that cannot tell whether a product is a dual-use item may ask the Ministry of Commerce (MOFCOM), giving its performance indicators and main uses (Regulations on the Export Control of Dual-Use Items, Article 14).
  • Dual-use exports go out under a single licence (up to 1 year), a general licence (up to 3 years) or an export certificate obtained by registration (Article 15).
  • The consignor presents the licence to customs; where customs has evidence that goods may be controlled, it can question the consignor and holds the goods meanwhile (Articles 21 and 22).
  • Exporting a controlled item without a licence is fined 5 to 10 times the illegal turnover where that is 500,000 yuan or more, and otherwise 500,000 to 5 million yuan (Export Control Law, Article 34).

How we help: Compliant Always keeps the classification reasoning and any licence or end-use document with the product, so the answer is on record when customs or a buyer asks. Ask about this

Encryption in consumer electronics

When commercial cryptography in a product needs an export licence.

  • Commercial cryptography used in mass-market consumer products is not subject to export control (Cryptography Law (密码法), Article 28, as quoted by the State Cryptography Administration).
  • Such products are those the public can buy without restriction through ordinary retail channels, for personal use, whose cryptographic function cannot easily be changed (State Cryptography Administration).
  • Items on the commercial cryptography export control list need a dual-use items and technologies export licence from MOFCOM (MOFCOM, State Cryptography Administration and GACC announcement, in force from 1 January 2021).

How we help: Compliant Always keeps the product's encryption description and the reasoning for its classification with the product, so the answer is on record when customs asks. Ask about this

Commodity inspection

Compulsory inspection of listed goods before export, and spot checks on goods outside the list.

  • GACC sets a catalogue of goods subject to compulsory inspection; listed export goods may not be exported until they pass (Law on Import and Export Commodity Inspection, Articles 4 and 5).
  • The consignor of listed goods reports them for inspection at the place and within the time set, and receives an inspection document (Article 15).
  • Goods that passed must be declared for export within the period set; after it, they are reported again (Article 16).
  • Makers of packaging for dangerous goods apply for a performance appraisal, and makers of dangerous goods for a use appraisal; dangerous goods in unappraised packaging may not be exported (Article 17).
  • From 1 June 2026, GACC spot-checks some goods outside the catalogue; the exports named include infant and child products (婴童用品) and low-voltage electrical apparatus (GACC Announcement No. 57 of 2026).
  • Exporting adulterated, counterfeit or substandard goods as good ones is fined 50% to 3 times the value of the goods (Article 33).

How we help: Compliant Always keeps test reports and inspection documents with the lot, dated, and shows which are missing or expired before the goods are declared. Ask about this

Export declaration and customs recordation

Who may declare goods for export, when, and with which documents.

  • The consignor of exported goods may declare to customs itself or authorise a customs declaration enterprise; either must complete recordation with customs in advance (GACC Decree No. 277, Article 4).
  • Declaration is made on the electronic customs declaration form; a paper form may be used only in special circumstances with customs' consent (Article 5).
  • Exported goods are declared after they arrive at the area under customs supervision and at least 24 hours before loading (Article 7).
  • The accompanying documents are the contract, invoice, packing list, manifest, bill of lading or waybill, power of attorney for customs declaration, export licences and other documents required by law; goods subject to inspection and quarantine need the documents set for them (Article 8).
  • The consignor and the declaration enterprise answer for the veracity, accuracy, integrity and compliance of what is declared (Article 6).
  • Recordation of a customs declaration entity is valid for a long time; changes to the name, domicile, legal representative or declaration personnel are reported within 30 days (GACC Decree No. 253, Articles 8 and 9).

How we help: Compliant Always keeps the contract, invoice, packing list and any licence with the shipment and lot, dated, and shows what is missing before the goods reach the port. Ask about this

Certificates of origin

Proof that goods originate in China, for non-preferential purposes and for preferential tariffs under trade agreements.

  • A consignor may apply for a certificate of origin to the inspection and quarantine authorities, now part of customs, or to the China Council for the Promotion of International Trade (CCPIT) and its local sub-councils (Regulations on the Origin of Import and Export Goods, Article 17).
  • The applicant registers with the issuing authority and declares origin truthfully; no certificate is issued for goods not originating in China (Articles 18 and 19).
  • Goods wholly obtained in China originate there; otherwise origin is where the last substantial transformation took place, judged first by a change in tariff classification (Articles 3 and 6).
  • Under RCEP, a Certificate of Origin is issued before shipment, or marked "ISSUED RETROACTIVELY"; China's issuing bodies are customs and CCPIT with their local branches (GACC Decree No. 255, Articles 19 and 42).
  • An approved exporter, which must be an Advanced Certified Enterprise, may issue its own declaration of origin under RCEP and the agreements with Iceland, Switzerland and Mauritius; the authorisation lasts 3 years (GACC Decree No. 254).
  • Consignors, manufacturers and approved exporters keep the documents proving origin for 3 years from issue (Decree No. 255, Article 41).
  • Obtaining a certificate by fraud, or forging or trading one, is fined 5,000 to 100,000 yuan (Regulations on Origin, Article 23).

How we help: Compliant Always keeps each certificate or declaration of origin with the shipment, beside the bill of materials it rests on, for the three years the records are kept. Ask about this

Who answers for what

WhoWhat they answer forHow we help
ManufacturerThe product's technical specifications, test evidence and, for dangerous goods, appraised packaging.Specifications and test reports kept with each model, ready for the exporter and buyer.
Exporter (consignor)Recordation with customs, a truthful export declaration and any licence the goods need.The shipment's documents kept together, dated, with the gaps shown before declaration.
Customs declaration enterprise or forwarderDeclaring within the authority the exporter gives it, under a power of attorney filed with customs.Answers to its questions taken from the record rather than from email threads.
MOFCOM and customsExport licences for controlled items (MOFCOM); release, questioning and inspection at export (customs).Licences and classification notes kept with the shipment.

Where are the goods going?

Most of what electrical and electronic products have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

Questions businesses ask

Do consumer goods need an export licence from China?
Only if they are controlled. Dual-use items on MOFCOM's control list need a licence, and so do other goods where the exporter knows or should know of a risk of weapons, terrorist or national security use (Export Control Law, Article 12).
Do consumer electronics with encryption need an export licence from China?
Commercial cryptography in mass-market consumer products is not subject to export control (Cryptography Law, Article 28). Items on the commercial cryptography export control list need a dual-use export licence from MOFCOM.
What counts as a mass-market consumer product for encryption?
One the public can buy without restriction through ordinary retail channels, for personal use, whose cryptographic function cannot easily be changed (State Cryptography Administration).
What if I cannot tell whether my product is a dual-use item?
Ask MOFCOM, giving the product's performance indicators, main uses and why you cannot tell; MOFCOM answers promptly (Regulations on the Export Control of Dual-Use Items, Article 14).
Which dual-use export licences exist in China?
A single licence for one export to one end user, valid up to 1 year; a general licence for repeated exports, valid up to 3 years; and an export certificate obtained by registering before each export (Article 15).
Can customs hold electronics it thinks may be controlled?
Yes. Where customs has evidence that goods may be dual-use items and no licence is shown, it questions the consignor and holds the goods meanwhile (Regulations on the Export Control of Dual-Use Items, Article 22).
Does China customs spot-check exported electrical goods?
From 1 June 2026, the exports named for spot checks outside the compulsory catalogue include low-voltage electrical apparatus and infant and child products (GACC Announcement No. 57 of 2026).
Do products shipped as dangerous goods need special packaging?
Yes. Makers of dangerous goods apply for a use appraisal of the packaging, and dangerous goods in unappraised packaging may not be exported (Law on Import and Export Commodity Inspection, Article 17).
When must goods be declared for export from China?
After they arrive at the area under customs supervision and at least 24 hours before loading. The consignor declares itself or through a customs declaration enterprise, both recorded with customs in advance (GACC Decree No. 277).
Who issues certificates of origin in China?
Customs and the China Council for the Promotion of International Trade (CCPIT) with its local branches. Approved exporters may issue their own declarations of origin under RCEP and some other agreements.
How does Compliant Always help with exporting from China?
Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

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