China’s Import and Export Licensing Regime in 2026

China’s Import and Export Licensing Regime in 2026

China’s import and export licensing regime in 2026 introduces several regulatory adjustments that directly impact companies engaged in cross-border trade. The updated licensing catalogues issued by the Ministry of Commerce (MOFCOM) and the General Administration of Customs (GACC) came into force at the beginning of 2026 and affect both importers and exporters operating in China.

These updates expand and refine licensing requirements across several categories, including non-automatic import licenses, automatic import licensing, export licensing, and dual-use item controls. For businesses shipping goods to or from China, understanding these regulatory changes is essential to avoid customs delays, compliance risks, and supply chain disruptions.

Overview of China’s Import and Export Licensing System

China maintains a structured licensing framework to regulate sensitive commodities, protect national security, manage strategic resources, and fulfill international obligations. In 2026, four main catalogues define which goods and technologies require licensing prior to import or export.

These four regulatory categories include:

These licensing regimes ensure that regulated goods are tracked and controlled before entering or leaving China’s customs territory.

Import Licensing Requirements in 2026

China requires import licenses for specific goods listed in the 2026 Import License Management Catalogue, which replaced the previous 2025 catalogue.

Products typically subject to import licensing include items with environmental, safety, or resource sensitivities, such as:

• Ozone-depleting substances

• Certain mechanical and electrical equipment

• Goods subject to national quotas or special administrative approvals

Import licenses are issued by MOFCOM or authorized provincial commerce departments. The license must be presented to Chinese customs during the import declaration process.

Changes in the 2026 Import Licensing Catalogue

The 2026 update introduces only minor administrative adjustments across the 14 product categories:

• The chemical HFC-23 was renamed with its full compound description “trifluoro methane (HFC-23)”.

• Several chemical codes were consolidated under a broader classification range.

• Two ship classification codes were merged into a single code due to tariff schedule reclassification.

Overall, these updates simplify product descriptions rather than introduce significant policy changes.

Automatic Import Licensing: Monitoring Key Imports

Automatic import licensing applies to goods that are monitored by authorities but not classified as restricted imports. Although approval is generally automatic, the license remains mandatory before customs declaration.

This licensing mechanism primarily serves two policy purposes:

• Monitoring import volumes and market trends

• Maintaining transparency under international trade obligations

Major Updates in 2026

The 2026 Automatic Import Licensing Catalogue introduces several notable adjustments:

• Restructuring of motor vehicle classifications under new HS codes

• Addition of whey as a newly controlled import category

• Expansion of fresh milk coverage to include all fat-content brackets

• Extension of soybean coverage to include black and green varieties

• Inclusion of modern nicotine products such as oral pouches and transdermal patches

• Detailed classification for drones and unmanned aerial vehicles

• Separate categories for bio-aviation kerosene and conventional aviation fuel

Although automatic licensing does not require discretionary approval, missing or delayed filings can still lead to customs clearance delays.

Export Licensing: Expanded Control Over Strategic Goods

China’s 2026 Export License Management Catalogue identifies 43 categories of goods requiring export licenses. Exporters must obtain approval before shipping these products abroad.

Key regulated export categories include:

• Agricultural staples such as wheat, corn, rice, and flour products

• Livestock and poultry exported to Hong Kong and Macao

• Coal, crude oil, and refined petroleum products

• Timber, cotton, and mineral resources

• Certain metals and chemical products

• Ozone-depleting substances

Depending on the product category, exporters may also need to provide supporting documentation such as quota certificates or tender results.

Key Changes in the 2026 Export Catalogue

The 2026 update introduces several important adjustments:

• A new sub-category for primary steel and iron products

• Expanded classifications for rare earth materials

• More detailed categories for strategic metals including tungsten, molybdenum, and titanium

• Removal of exemption markers related to antimony exports

• Addition of bio-aviation kerosene classification

• New category for electric vehicles (non-used, VIN-coded)

These changes reflect China’s increased focus on regulating strategic materials and advanced industrial sectors.

Dual-Use Items and Technology Licensing

Dual-use controls apply to goods and technologies that may have both civilian and military applications.

The 2026 Dual-Use Items and Technology Import/Export Catalogue significantly expands the scope of controlled items compared with the 2025 version.

The catalogue now includes approximately 80 to 85 newly controlled items, expanding from 161 pages to 168 pages.

Newly Controlled Strategic Materials

Several sectors receive additional regulatory coverage, including:

• Drug precursor chemicals such as fentanyl-related derivatives

• Heavy tungsten-nickel alloys

• Missile-related molybdenum powder

• Rare earth materials such as samarium compounds

• Semiconductor materials containing indium

• Bismuth and tellurium materials used in radiation detection and thermoelectric applications

The catalogue also introduces technology controls covering production know-how and manufacturing techniques.

For certain imports, such as radioactive isotopes, companies must first obtain approval from the Ministry of Ecology and Environment before applying for a dual-use license from MOFCOM.

Industries Most Affected by the 2026 Updates

The regulatory updates affect companies differently depending on their products and trade structures.

Importers

Businesses importing the following goods may face greater regulatory exposure:

• Industrial chemicals and regulated substances

• Mechanical equipment and machinery

• Used equipment or spare parts

• Non-standard shipments such as samples, donations, or returned goods

High-volume importers relying on rapid supply chains must ensure automatic licensing requirements are fulfilled before shipment.

Exporters

Exporters dealing in regulated goods will be particularly affected, including companies exporting:

• Quota-controlled commodities

• Strategic metals and materials

• Agricultural staples

• Energy products

Exporters involved in processing trade or border trade may also face additional documentation requirements.

Dual-Use Technology Companies

Companies working with advanced materials, chemicals, aerospace components, or semiconductor technologies must carefully evaluate whether their products fall under dual-use regulations.

Compliance Strategies for Businesses

To minimize regulatory risks and maintain smooth trade operations, companies should adopt proactive compliance strategies.

1. Re-screen Product Classifications

Businesses should re-evaluate their product classifications against the 2026 catalogues rather than relying on prior-year classifications.

2. Plan Licensing Lead Times

Shipping schedules should account for licensing processing times, quota allocations, and regulatory approvals.

3. Establish Clear Internal Responsibilities

Coordination between compliance teams, logistics departments, customs brokers, and trade managers is essential to ensure licensing requirements are addressed before shipment.

4. Prepare Accurate Documentation

Companies should prepare detailed product specifications and ensure consistency across contracts, invoices, and shipping documentation.

5. Evaluate Trade Modes

Exporters should determine whether shipments fall under general trade, processing trade, border trade, or quota-controlled regimes before signing contracts.

6. Monitor Dual-Use Risk

When goods may fall under dual-use controls, companies should follow the dual-use licensing procedure rather than relying solely on HS code classification.

Conclusion

China’s 2026 import and export licensing updates reinforce the importance of proactive trade compliance for companies engaged in cross-border business. The revised catalogues introduce expanded monitoring, more detailed classifications, and broader controls over strategic materials and technologies.

Businesses that treat annual licensing updates as routine administrative changes may face shipment delays, contractual complications, or regulatory exposure. In contrast, companies that proactively review product classifications, align shipping schedules with licensing requirements, and implement strong internal compliance processes can reduce operational disruptions and maintain stable supply chains throughout 2026.