Goods listed in the controlled catalog, even if not originating from China, still need to obtain a dual-use item export license in accordance with regulations when applying for exit declaration, provided that they meet the domestic regulatory circulation requirements.

In practical declaration, the core criterion for determining the supervision of dual-use item exports is based on the HS code of the goods, with the corresponding customs supervision document code being "3". This serves as the core basis for customs declaration and document review. This supervision attribute does not rely on the origin of the goods as a selection criterion; rather, it primarily depends on the circulation scenario and supervision status of the goods.

📌 Define control boundaries based on the physical supervision status of goods

For the bonded entrepot trade scenario involving goods that are imported into warehouses and then re-exported, once the goods actually enter China's customs territory, including special customs supervision areas such as comprehensive bonded zones and bonded warehouses, as well as bonded supervision areas, customs will uniformly exercise control in accordance with the export supervision criteria during the subsequent declaration for exit.

As long as the goods are listed in China's "Dual-use Items Export Control List", regardless of their overseas origin, as long as they undergo bonded warehousing, transit and standby, and then exit the country for circulation throughout the entire process, they fall under the scope of statutory control. Therefore, it is necessary to apply for the corresponding dual-use items export license in advance before they can be declared for export in compliance.