Do dual-use items and technologies listed in the "Catalogue of Dual-Use Items and Technologies Subject to Import and Export License Administration (2024)" require an export license when they are in transit, transshipment, or pass-through?

Article 45 of the "Export Control Law of the People's Republic of China" stipulates that the transit, transshipment, pass-through, re-export, or export from bonded areas, export processing zones, and other customs special supervision areas and export supervision warehouses, bonded logistics centers, and other bonded supervision locations to overseas shall be carried out in accordance with the relevant provisions of this law.

Furthermore, Article 6 of the "Measures for the Administration on Import and Export License for Dual-use Items and Technologies" stipulates that any import or export, as well as transit, transshipment, or pass-through of dual-use items and technologies listed in the "Catalogue," must apply for a dual-use items and technologies import or export license.

The provisions of the previous paragraph apply to the movement of dual-use items and technologies between overseas locations and bonded areas, export processing zones, and other customs special supervision areas, bonded locations.

The movement of dual-use items and technologies within domestic and bonded areas, export processing zones, and other customs special supervision areas, bonded locations, or between these customs supervision areas and bonded locations does not require a dual-use items and technologies import or export license.

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