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China Adds Tunnel Boring Machines and Other Equipment to Export Control List: What Foreign Founders Need to Know
China's Ministry of Commerce and General Administration of Customs Announcement No. 50 of 2026 imposes export controls on tunnel boring machines, walking excavators, and high-altitude wet shotcrete machines. The rules take effect on November 18, 2026. Foreign founders operating in China should understand licensing requirements, customs declaration obligations, and compliance risks.
New Export Controls on Construction Equipment
On October 19, 2026, China's Ministry of Commerce (MOFCOM) and the General Administration of Customs issued Announcement No. 50 of 2026, introducing export controls on certain dual-use items related to tunnel boring machines, walking excavators, and high-altitude wet shotcrete machines. The measure is based on China's Export Control Law, Foreign Trade Law, Customs Law, and Regulations on Export Control of Dual-Use Items, and was approved by the State Council to safeguard national security and interests. The announcement takes effect on November 18, 2026, and the Dual-Use Items Export Control List will be updated accordingly.
Which Items Are Controlled?
The controls cover three categories of equipment and related components, technologies, and software. Foreign founders whose China-based companies manufacture, trade, or re-export these items should review their product portfolios carefully.
1. Tunnel Boring Machines and Related Items
- 2B906 – Full-face tunnel boring machines: Earth pressure balance shield machines, slurry shield machines, and other types of shield machines (HS code reference: 8430313010); open-type, single-shield, double-shield rock tunnel boring machines, and other rock TBMs (HS code reference: 8430313010).
- 2A906 – Components specially designed for 2B906 items: cutterheads (HS 8431499910), screw conveyors (HS 8428310010), segment erectors (HS 8479899959), main drive systems and other key units (HS 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 8429521920): ability to cross vertical obstacles over 1.2 m; wading depth over 1.5 m; trench crossing width over 3 m; walking gradeability over 40°.
- 2E904 – Electro-hydraulic proportional control technology for hydraulic systems specially designed for 2B904 items.
Technical note: A walking excavator is defined as mechanical equipment that uses combined actions of its working device, outriggers, or wheels to achieve self-propulsion, enabling multifunctional excavation across all terrains.
3. High-Altitude Wet Shotcrete Machines and Related Items
- 2B903 – High-altitude wet shotcrete machines for use above 3,000 m altitude, with all of the following (HS 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 – Components specially designed for 2B903 items: high-altitude engines with max power over 75 kW and torque over 680 N·m (HS 8408909240, 8408909330); engine auxiliary oxygen supply devices (HS 8421399030); high-altitude motors with max power over 55 kW (HS 8501520020, 8501530020); two-stage air compressors with displacement over 15 m³/min (HS 8414804110); high-altitude chassis (HS 8479909030); folding arms (HS 8479909030).
- 2E903 – Hydraulic and pumping technology specially designed for 2B903 items.
Technical note: A high-altitude wet shotcrete machine is equipment that transports mixed materials (such as concrete) to a nozzle in plateau areas, adds air and accelerator, and sprays the material onto the working surface.
Licensing Requirements for Exports
Exporters intending to ship the controlled 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 Regulations. Without a license, such exports are prohibited. For exports to other countries and regions worldwide, exporters can obtain an export voucher by registering and submitting information. Both exporters and end-users must commit not to transfer or provide China-origin controlled items to countries or regions with disputes with China without a license. Organizations and individuals outside China are also prohibited from transferring or providing China-origin controlled 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 export items. If an item is controlled, the remarks column of the customs declaration must state “属于两用物项” (dual-use item) and include the dual-use export control code. If an item is not controlled but its parameters, indicators, or performance are close to the controlled thresholds, the remarks column must state “不属于管制物项” (not a controlled item) and provide specific parameters and indicators. Customs may question declarations where information is incomplete, inaccurate, or doubtful; goods will not be released during the questioning period.
Practical Implications for Foreign Founders
Foreign founders with manufacturing or trading operations in China should take several steps. First, review product lines and technical specifications against the control lists to determine whether any items fall within the scope. Second, update internal compliance procedures to ensure customs declarations are accurate and include required remarks. Third, for exports to sensitive destinations, obtain the necessary license before shipment. Fourth, for exports to other destinations, complete the registration and obtain the export voucher, and ensure end-users sign the required commitments. Finally, monitor the updated Dual-Use Items Export Control List, effective November 18, 2026, and train staff accordingly.
Given the technical thresholds and the potential for customs questioning, it is advisable to document product parameters thoroughly and consult with trade compliance professionals. Non-compliance can lead to shipment delays, penalties, or legal liability under Chinese law.
Next Steps
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.