Publié le · France

China Expands Export Controls on Tunnel Boring Machines, Walking Excavators, and High-Altitude Wet Sprayers

New MOFCOM and GAC Announcement No. 50 of 2026 adds dual-use export controls on specified construction machinery and components, effective November 18, 2026. Foreign founders in China must comply with licensing and registration requirements.

New Export Controls on Construction Equipment

On October 19, 2026, China's Ministry of Commerce (MOFCOM) and General Administration of Customs (GAC) issued Announcement No. 50 of 2026, introducing export controls on certain dual-use items, including tunnel boring machines, walking excavators, and high-altitude wet sprayers. The measures are based on the Export Control Law, Foreign Trade Law, Customs Law, and Regulations on Export Control of Dual-Use Items, and are stated to safeguard national security and interests. The controls take effect on November 18, 2026, and the Dual-Use Items Export Control List will be updated accordingly.

For foreign founders operating manufacturing, construction equipment, or trading companies in China, these new controls mean that exporting the listed items—or supplying them to certain destinations—will require prior authorization or registration. Understanding the scope and compliance steps is essential to avoid shipment delays or penalties.

Items Subject to Export Controls

The announcement categorizes controlled items under three groups, each with specific technical parameters and customs commodity codes.

1. Tunnel Boring Machines and Related Items

• 2B906 – Full-face tunnel boring machines: Includes earth pressure balance shield machines, slurry shield machines, and other shield machines (HS code 8430313010); open-type, single-shield, double-shield rock tunnel boring machines, and other rock TBMs (HS code 8430313010).
• 2A906 – Parts specially designed for 2B906 items: Cutterheads (HS code 8431499910); screw conveyors (HS code 8428310010); segment erectors (HS code 8479899959); main drive systems and other key units (HS code 8431499910).
• 2E906 – Remanufacturing technology specially designed for 2A906 or 2B906 items.

2. Walking Excavators and Related Items

• 2B904 – Walking excavators with any of the following characteristics (HS code 8429521920): capable of crossing vertical obstacles over 1.2 m; wading depth over 1.5 m; crossing trenches wider than 3 m; or climbing slopes over 40°.
• 2E904 – Hydraulic system electro-hydraulic proportional control technology specially designed for 2B904 items.

Technical note: A walking excavator is defined as mechanical equipment that uses combined actions of working devices, outriggers, or wheels to achieve self-propulsion for multifunctional excavation on all-terrain surfaces.

3. High-Altitude Wet Sprayers and Related Items

• 2B903 – High-altitude wet sprayers for use above 3,000 m altitude, with all of the following (HS code 8479109010): engine maximum power over 75 kW and torque over 680 N·m; motor maximum power over 55 kW; pumping system suction efficiency above 95%; air compressor displacement over 15 m³/min; low-temperature hydraulic oil usable at -20°C.
• 2A903 – Parts specially designed for 2B903 items: High-altitude engines with max power over 75 kW and torque over 680 N·m (HS codes 8408909240, 8408909330); engine auxiliary oxygen supply devices (HS code 8421399030); high-altitude motors with max power over 55 kW (HS codes 8501520020, 8501530020); two-stage air compressors with displacement over 15 m³/min (HS code 8414804110); high-altitude chassis (HS code 8479909030); folding arms (HS code 8479909030).
• 2E903 – Hydraulic and pumping technology specially designed for 2B903 items.

Technical note: A high-altitude wet sprayer is equipment that transports mixed materials (such as concrete) to a nozzle in high-altitude areas and sprays them onto the working surface by adding air and accelerator.

Export Licensing and Registration Requirements

Exporters shipping any of the above items to sensitive countries and regions that have disputes with China must apply to the State Council's commerce department for a license under the Export Control Law and the Dual-Use Items Export Control Regulations. Without a license, no export to those destinations is permitted. For exports to all other countries and regions, exporters must obtain an export certificate through registration and information filing. Both the exporter and the end user must commit not to transfer or provide the China-origin items to countries or regions with disputes with China without authorization. Organizations and individuals outside China are also prohibited from transferring or providing China-origin items to such sensitive destinations without a license.

Customs Declaration Obligations

Exporters are responsible for the authenticity of customs declarations and must strengthen the identification of exported items. If an item is controlled, the remarks column of the customs declaration must state "belongs to dual-use items" and list the dual-use export control code. If an item is not controlled but its parameters, indicators, or performance are close to controlled thresholds, the remarks column must state "does not belong to dual-use items" and provide the specific parameters. Customs will challenge declarations with incomplete, inaccurate, or doubtful information, and goods will not be released during the challenge period.

Practical Steps for Foreign Founders

Foreign founders with Chinese companies involved in the manufacture, trade, or export of construction machinery should take immediate action:

• Review product portfolios against the technical parameters and HS codes listed in the announcement to determine whether any items are controlled.
• Map end users and destinations to identify whether any shipments are destined for sensitive countries or regions.
• Implement internal compliance procedures to ensure accurate customs declarations, including proper remarks and coding.
• Train staff on the new requirements and update contracts to include end-user commitments.
• Consult legal advisors if uncertain about classification or licensing.

Given the effective date of November 18, 2026, companies should prepare now to avoid disruptions. Non-compliance can result in customs delays, fines, or other penalties under Chinese law.

Call to action: Foreign founders can contact ChinaMNC on WhatsApp / WeChat at +86 153 1898 8535 for help registering and operating a company in China.

This summary is based on information published by the relevant Chinese government website and is general information, not legal or tax advice.