China’s Import and Export Licensing Regime in 2026

China import export licensing regime in 2026 brings changes that affect both importers and exporters operating in China. The updated catalogs introduce new requirements for non‑automatic licensing, automatic import licensing, export licensing, and dual‑use controls. Companies must screen their products and align compliance workflows early to avoid delays and regulatory risks.

China’s Ministry of Commerce (MOFCOM) and the General Administration of Customs (GACC) released the updated import and export licensing catalogues in late 2025, with the new requirements taking effect at the start of 2026. Because these annual updates become operational immediately in early January, they can have direct implications for cross‑border trade. Companies shipping goods during this period face a heightened risk of clearance delays, disrupted delivery timelines, and follow‑on contractual or compliance issues if licensing obligations are misclassified or overlooked. These risks are particularly pronounced in 2026 for chemicals, regulated industrial inputs, and machinery, where licensing determinations often rely on detailed product descriptions and technical parameters rather than HS codes alone.

China’s import and export licensing schemes for 2026

China’s import and export licensing regime in 2026 remains a structured system designed to regulate restricted commodities, safeguard national security, manage resource‑related goods, and ensure alignment with international obligations. MOFCOM and GACC maintain four main catalogues outlining goods or technologies that require licensing before they may be imported or exported:

• Import license (进口许可证)
• Automatic import license (自动进口许可证)
• Export license (出口许可证)
• Dual‑use items and technologies license (两用物项和技术进出口许可证管理目录)

Import licensing

China requires import licenses for specific categories of goods listed in the 2026 Import License Management Catalogue, issued under MOFCOM GACC Announcement 2025 No. 88 and effective January 1, 2026, replacing the previous catalogue, MOFCOM GACC Announcement 2024 No. 66.

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

• Ozone‑depleting substances
• Certain mechanical and electrical products
• Goods subject to national quota allocation or other special approval mechanisms

Licenses are issued by MOFCOM or authorized provincial commerce departments and must be presented to Customs at the time of import.

Automatic import licensing

Automatic import licensing applies to goods that remain under monitoring but are not classified as restricted. These goods are listed in the Automatic Import License Catalogue, which operates in parallel with China’s main import administration regime.

Automatic licensing serves two primary policy objectives:

• Monitoring import volumes and market conditions
• Ensuring compliance with WTO transparency requirements

Licenses under this regime are generally issued automatically upon application.

China has updated its Automatic Import Licensing Catalogue for 2026, effective January 1, 2026, with the exception of whey, which is subject to a later implementation date of January 22, 2026. While automatic licenses do not involve substantive approval, they remain mandatory for customs clearance. Notably, fertilizer imported under processing trade (catalog items 18 and 33) must present an automatic import license at declaration. The new catalogue repeals MOFCOM GACC Announcement 2024 No. 64, which governed the earlier version. Missing or late filings may still result in clearance delays, particularly early in the implementation period.

Export licensing

The 2026 Export License Management Catalogue, issued under MOFCOM GACC Announcement 2025 No. 89, designates 43 categories of goods requiring export licensing. The catalogue took effect on January 1, 2026.

Key categories subject to export control include:

• Agricultural staples (wheat, corn, rice, flour products)
• Livestock and live poultry exported to Hong Kong and Macao
• Coal, crude oil, and refined oil products
• Timber, cotton, and various minerals
• Ozone‑depleting substances
• Selected metals and chemical products

Certain items require supporting documentation, such as quota certificates or bidding results, depending on the specific product.

Dual‑use items and technologies licensing

China has also released the 2026 Dual‑Use Items and Technologies Import/Export License Management Catalogue, the MOFCOM GACC Announcement 2025 No.91, which governs goods and technologies with potential military or proliferation-sensitive applications.

For specific imports, such as radioactive isotopes, enterprises must first obtain approval from the Ministry of Ecology and Environment (MEE), followed by a dual‑use import issued by MOFCOM’s Quota and License Affairs Bureau.

When an item falls under the dual‑use control system, companies must complete the dual‑use licensing procedure and verify whether ordinary export licensing additionally applies.

What has been changed for 2026

General import licensing

The 2026 Import License Administration Catalogue contains only three changes across all 14 categories. In the ODS (ozone-depleting substances) section, HS code 3827510000 received a minor wording tweak, explicitly naming the compound as “trifluoro methane (HFC-23)” rather than just “HFC-23.” HS code 3827680000 saw the most substantive revision: instead of listing 10 individual HS codes in the description, the 2026 version consolidates them into a shorthand reference to the subheading range “2903.41–2903.48,” and drops the explicit exclusion clause for CFCs and HCFCs. In Category 12 (Ships), two previously separate codes, 8901101010 (high-speed passenger vessels) and 8901101090 (other motorized ferries and cruise ships), have been merged into a single code, 8901101000, reflecting a tariff schedule reclassification with no practical change to the goods covered.

All other content, the remaining line items across all 14 categories and all four explanatory notes, is identical between the two versions. Overall, the 2026 update is a minor administrative revision focused on simplifying descriptions and consolidating ship classifications rather than any substantive policy change.

For a more detailed comparison of the 2025 and 2026 catalogues, please click here.

Automatic import licensing

China’s Automatic Import Licensing Catalogue for 2026 introduces several notable changes from its 2025 predecessor. Most significantly, the entire motor vehicle classification (HS 87.03) has been restructured under new 10-digit subheadings, requiring all vehicle importers to verify and update their commodity codes. A new commodity category, whey, has been added, meaning whey importers will now require an automatic import license for the first time.

Coverage has also been broadened across several existing categories. Fresh milk now encompasses all fat-content brackets rather than just the lowest tier, and soybeans have been extended to include black and green varieties. The tobacco and nicotine section sees the most expansive update, with six new codes bringing modern non-combustion nicotine products, such as oral pouches and transdermal patches, under automatic import licensing control. Aviation kerosene has been split into separate bio and conventional fuel codes. In Part II, olive oil, a comprehensive range of vessel sub-types, and a detailed UAV/drone classification grid across all weight brackets have all been newly added.

For a more detailed comparison of the 2025 and 2026 catalogues, please click here.

Export licensing

The 2026 catalogue’s most significant addition is an entirely new sub-category of primary steel and iron products under item 32, covering dozens of HS codes for pig iron, steel scrap, billets, rolled plates, coils, bars, tubes, pipes, and fittings. The rare earth section (item 22) has been substantially expanded with more granular classifications, particularly for mid-to-heavy rare earths including samarium, gadolinium, and lutetium compounds. Several strategic metals, tungsten, molybdenum, and titanium, have had their powder/product codes split into more specific sub-classifications. Antimony entries have had their dual-use permit exemption markers (*) removed, and the related general exemption note from the 2025 catalogue is deleted entirely. Silver gains new entries for tungsten-doped alloys. In petroleum products, bio-aviation kerosene is newly separated from conventional aviation kerosene. A new electric vehicle category (non-used, VIN-coded) is added under item 43. Minor administrative changes include a unit reversal for rush grass cushions and a diesel code update.

For a more detailed comparison of the 2025 and 2026 catalogues, please click here.

Dual-use items and technology licensing

China’s 2026 Dual-Use Items and Technology Import/Export License Management Catalogue reflects a significant expansion and systematization of export controls compared with the 2025 edition. The catalogue grows from 161 to 168 pages, adding approximately 80-85 new controlled items. Most notably, the legal basis in the preamble shifts from referencing a specific 2024 inter-agency announcement to the broader PRC Dual-Use Items Export Control List, signaling alignment with a more consolidated and institutionalized export control framework.

Substantively, the 2026 edition introduces new controls across several strategic sectors. These include additional drug precursor chemicals (notably piperidone and fentanyl-related derivatives), new heavy tungsten-nickel alloys (1C004), missile-related molybdenum powder and solid tungsten (1C117), samarium rare earth materials (1C902), indium-based semiconductor materials (3C004), and a new Category 6C covering bismuth and tellurium materials used in infrared, thermoelectric, and radiation detection applications. Corresponding technology controls (1E, 3E, and 6E categories) have also been added, extending regulation to production know-how.

In parallel, the catalogue updates numerous HS customs codes, particularly for UAVs, and clarifies technical descriptions, exemptions (for example, small lithium-thionyl chloride batteries), and nuclear material terminology. Overall, the 2026 revision broadens material, chemical, and technology controls while refining classification and legal coherence.

For a more detailed comparison of the 2025 and 2026 catalogues, please click here.

Who is most affected by the 2026 licensing updates

China’s 2026 updates to its import and export licensing catalogs will affect companies differently, depending on product type, trade structure, and shipment timing.

Regarding imports, automatic import licensing primarily impacts companies that import goods listed in the 2026 catalogues, especially those with high-volume or time-sensitive supply chains. Businesses that assume automatic licenses are optional or can be completed post-arrival face a higher risk of customs delays. Under the non-automatic import licensing regime, importers of regulated substances and chemicals face greater exposure, as do companies importing industrial equipment and machinery, including used equipment, spare parts, and project cargo. Non-standard shipments, such as samples, returned goods, donations, and residual materials, are also frequently affected.

Regarding exports, the 2026 export licensing catalogue affects exporters of listed goods, particularly those dealing in quota-controlled products, for which license issuance depends on proof of quota or tender documentation. Processing and border small trade exporters face additional complexity due to documentation rules specific to the trade mode. Exporters of regulated goods should also assess their potential exposure to dual-use controls.

Finally, dual-use licensing affects importers and exporters of controlled items and technologies, including those handling sensitive materials or products whose technical parameters may trigger export control requirements.

What companies should do now

Companies affected by the 2026 licensing updates should first re-screen their products against the latest import, export, automatic import, and dual-use catalogue. Rather than relying on prior-year classifications, they should update their SKU mappings.

They should also realistically plan license lead times by factoring in licensing, quota allocation, automatic license filing, and any required pre-approvals when setting delivery schedules and Incoterms.

Clear internal responsibilities should be established between the importer or exporter of record, customs brokers, and internal compliance or supply chain teams. This will ensure that license requirements are identified and addressed before shipment.

Companies should also prepare documentation early. This includes accurate product specifications, technical parameters, and end-use or end-user explanations when required. Companies should ensure consistency across contracts, invoices, and shipping documents.

Additionally, businesses should account for trade modes and quota regimes. They should confirm whether exports fall under general trade, processing trade, border small trade, or quota-linked administration before executing contracts.

Finally, companies should carefully manage dual-use and overlap risk. If goods may fall under dual-use or temporary control, follow the dual-use licensing track and avoid relying on HS code screening alone.

Key takeaways

China’s 2026 licensing updates reinforce that cross-border compliance extends well beyond matching products to customs codes. Companies now need earlier-stage product classification, deeper technical assessment, and closer coordination among commercial, logistics, and compliance functions. Treating the annual January catalogue update as a routine administrative exercise increases the likelihood of shipment delays, contractual friction, and regulatory exposure. In contrast, proactive product reclassification, alignment of licence lead times with shipping schedules, and careful review of potential dual-use overlaps help reduce disruption, protect supply chain continuity, and contain compliance risks throughout 2026.

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