Direct answer: An export-control and end-user statement page cannot just say "we comply with export-control laws." It should state whether the product may fall within the dual-use list, whether there is "knowledge or should-have-known" risk outside the list, which licence applies (single, general, or registration-based export certificate), what an end-user/end-use statement must contain, how to verify customer documents, how the internal compliance programme runs, how the watch list and control list are checked, how customs queries are handled, how transit/transshipment/re-export is treated, how long records are kept, and what must not be published. Otherwise, when a customer asks "does this model need a licence?" or "can you sign an end-user statement?", sales can only ask someone else.
This guide is for export, customs, legal, quality, engineering, and website teams at manufacturers in Changzhou and nearby industrial areas. It explains how to build and accept an export-control and end-user statement page. Information is current to 2026-11-02. It is a review of public regulations and project practice, not legal, export-control, customs, or compliance advice; specific classification, licence applications, end-user review, and customs handling depend on the Export Control Law, the Dual-Use Items Regulation, and the rules of the competent authorities and customs.
Export control is not "only what is on the list": listed items need a licence, and items outside the list also need one if the exporter knows or should know of the risk. An end-user/end-use statement is not a promise written by sales—it is issued by the end user, and may also need to be issued or certified by that country's government. The website can publish the compliance statement and process, but not specific licence numbers, customer information, item technical parameters, or internal classification conclusions.
How does the export-control page relate to documents, product compliance, technical data, and after-sales pages?
The documents page answers "what paperwork for customs"; the product-compliance page answers "how to declare CE/RoHS/REACH"; the technical-data page answers "who gets drawings and how"; the after-sales page answers "how repairs work"; the export-control page answers "can this item leave, does it need a licence, who is the end user, what is the use, how long are records kept." Export control is the "may we trade" gate; documents and customs are the "how to deliver" step. If the gate is missed, perfect paperwork can still be stopped at the border.
The common break is: sales assumes "our product is ordinary and not on the list"; a customer asks for an "export-control statement" and the company downloads a template; the end-user statement has only a buyer's signature, no company letterhead or use; at licence application the technical description and test report do not match; at a customs query there is no contract, performance data, or end-use explanation; records sit in a personal mailbox and cannot be found three years later. A page that states the screening entry, statement elements, licence process, and record rules gives sales, customs, and legal one playbook.
| Page/entry | Answers | Audience | Cannot replace |
|---|---|---|---|
| Export-control page | Controlled or not, licence type, statements, records | Export, customs, legal | Specific classification conclusion |
| Documents page | Invoice, packing list, B/L, origin certificate | Customs, documentation | Licence and end-user review |
| Product compliance page | CE, RoHS, REACH, test reports | Quality, engineering | Dual-use list screening |
| Technical data page | Tiers, NDA, watermark, download logs | Engineering, sales | Control status of technology |
| After-sales page | Repair, spares, remote support | Service, customer | Technology export in servicing |
This page map is editorial; the basic regime is in the Export Control Law.
Which products may be controlled, and how do you screen?
Screen three lines: items on the dual-use export-control list need a licence; items under temporary control also need one; outside both, if the exporter knows or should know—or is notified by the competent authority—that goods, technology, or services may endanger national security and interests, be used for weapons of mass destruction and their means of delivery, or be used for terrorism, a licence must also be applied for. If it cannot be determined, the exporter may consult the competent authority.
"Our product is a general part" is not an exemption. The same machine can fall in or out of the list depending on parameters, precision, materials, and software functions; technical documents, source code, process parameters, and remote-maintenance access may also constitute an export of technology. Screening must land on five fields—model, parameters, use, destination, end user—not one sentence saying "not controlled." The list is published by MOFCOM, MIIT, the General Administration of Customs, and the State Cryptography Administration; the list under Announcement No. 51 of 2024 took effect on 2024-12-01, and whether a specific model falls within it still requires item-by-item comparison with the list entries and technical parameters.
| Scenario | Licence needed? | Basis | Common gap |
|---|---|---|---|
| Listed item | Apply for a licence | Export Control Law Art. 12 | Name only, no parameters |
| Temporarily controlled item | Apply for a licence | Arts. 9 and 12 | Unaware of temporary control |
| Not listed but known risk | Apply for a licence | Art. 12 | "Not listed" means go |
| Uncertain | May consult the authority | Art. 12 | Guessing |
| Technology/software/services | May be controlled | Arts. 2 and 45 | Only watching goods |
| Transit/transshipment/re-export | Governed by the Law | Art. 45 | Assuming direct export only |
This screening is editorial; list entries, parameters, and temporary controls follow MOFCOM Announcement No. 51 of 2024 and the latest authority announcements.
What licence types exist?
Dual-use exports use three routes: a single licence, a general licence, or a registration-based export certificate. A single licence covers one specific export to a single end user and is valid for no more than one year; a general licence covers multiple specific exports to one or more end users and is valid for no more than three years; the registration route requires registration before each export, truthful filing, and an export certificate before self-export. Which applies depends on the item, end user, channel, and the company's internal compliance performance.
A general licence is not "export freely": it requires an internal compliance programme that is established and operating well, relevant export records, and relatively stable channels and end users, plus a statement on ICP operation, licence use, channels, and end users. A single licence requires identity documents, a copy of the contract, technical description or test report, end-user and end-use certificates, and other materials. The page can explain the scenarios but must not tell a customer "you will certainly get a general licence."
| Type | Scope and limits | Validity | Common gap |
|---|---|---|---|
| Single licence | One end user, one specific export | Up to 1 year | One licence, many uses |
| General licence | One or more end users, multiple exports | Up to 3 years | Applied without ICP |
| Registration certificate | Register before each export, then self-export | Per shipment | Export first, register later |
| Single-licence materials | ID, contract, technical description/test report, end-user certificate | — | Contradictory documents |
| General-licence materials | Plus ICP operation, licence use, channel and end-user statements | — | ICP on paper only |
Licence types and materials are in Articles 15 and 16 of the Dual-Use Items Regulation; the authority decides specific eligibility.
What must an end-user and end-use statement contain?
A usable statement contains at least: the end user's full legal name, registered address, and registration number; the end use (specific product, line, or project—not "industrial use"); item name, model, and quantity; an undertaking not to change the end use or transfer to any third party without Chinese authority approval; signatory name, title, contact, signature, company seal, and date; and, where required, a document issued or certified by the end user's government. The statement is issued by the end user, not written by the exporter as "the customer says it is civilian."
Article 15 of the Export Control Law requires the exporter to submit end-user and end-use certificates issued by the end user or by the government of the end user's country or region; Article 16 requires the end user to undertake not to change the use or transfer to a third party without approval. Article 24 of the Regulation further allows the authority to require certificates issued or certified by the end user's government. A statement is not "one-off": if the end user, use, or destination changes, or a document is forged, altered, or expired, the exporter must stop the export and report.
| Element | What to state | Evidence | Common gap |
|---|---|---|---|
| Entity | Full name, address, registration, contact | Licence/registration | Buyer's business card only |
| End use | Specific product/line/project | Project description | "Industrial use" |
| Item | Name, model, quantity, parameters | Contract/invoice | Mismatch with contract |
| Undertaking | No change of use, no transfer | Statement clause | Seal without undertaking |
| Signature | Name, title, signature, seal, date | Original/scan | Unauthorised signer |
| Government certification | Issued/certified where required | Certified document | Cannot provide |
These elements are editorial; the legal requirements are in Articles 15 and 16 of the Export Control Law and Article 24 of the Regulation.
How should customer documents be verified?
Verify in five steps: entity authenticity, use plausibility, item consistency, signature validity, and document currency. Check whether the entity matches the buyer/end user in the contract, whether the use fits the product's capability, whether model and quantity match the contract and invoice, whether the signatory is authorised and the seal is the company seal, and whether the document is valid and unaltered. If the use clearly does not match the product (for example, high-precision equipment described for an implausible scenario), the end user differs from the buyer, or the document comes from a free email account, escalate—do not release.
Verification is not "received, therefore done." Keep a record: who checked, what was checked, what was found, and how it was handled. For importers or end users on the watch list, a general licence or a registration-based certificate may not be used; a single-licence application requires a risk assessment report and a compliance undertaking. For those on the control list, transactions must not violate the rules. The website can say "we review end users," but should not publish the detailed checklist or customer information.
| Check | What to verify | Evidence | Common gap |
|---|---|---|---|
| Entity | Buyer = end user? Registration verifiable? | Registration/website | Intermediary stands in |
| Use | Fits capability, industry, capacity | Project/site | Vague |
| Item | Model/quantity/parameters match | Contract/invoice | Model mismatch |
| Signature | Authorised person, company seal, date | Authorisation | Individual signature |
| Currency | Validity, alterations, reuse | Original | One paper, many uses |
| Lists | Watch list / control list | Search record | Not checked |
This method is editorial; watch-list and control-list handling is in Articles 26 and 28 of the Regulation and Article 18 of the Export Control Law.
How should an internal compliance programme be built?
An ICP covers at least: organisation and responsible person, item classification and list comparison, end-user and end-use review, licence application and certificate management, customs and logistics handover, exception and suspected-violation reporting, training and assessment, record-keeping and audit, and third-party (agent/freight forwarder/broker) management. The programme must be shown to operate—training records, review records, licence ledgers, exception handling, and internal audit reports—not just a manual on the shelf.
Article 14 of the Export Control Law allows the authority to grant general licences and other facilitation to exporters with a well-operating ICP; Article 16 of the Regulation requires an ICP operation statement for a general licence. For an SME, start with "one form, one person, one training": an item-and-customer review form, a compliance owner, and one training covering sales, customs, and engineering, then add audit and system trails. The website can say "an ICP is established" but must not say "approval guaranteed."
| Module | What to do | Evidence | Common gap |
|---|---|---|---|
| Organisation | Compliance owner, cross-team duties | Appointment | Nobody owns it |
| Classification | List comparison, parameters, consultation | Classification form | Experience only |
| Review | End user, use, lists | Review record | Contract only |
| Licence | Application, ledger, validity, changes | Licence ledger | Expired |
| Handover | Customs presentation, forwarder/broker notice | Handover sheet | Logistics unaware |
| Exception | Stop, report, cooperate | Report record | Ship first |
| Training/audit | Annual training, internal audit, remediation | Attendance/report | Manual on the wall |
These modules are editorial; facilitation is in Article 14 of the Export Control Law, and materials in Article 16 of the Regulation.
How should the watch list and control list be used?
Treat them separately. The watch list targets importers and end users that fail to cooperate with end-user/end-use verification within the deadline, making verification impossible; exports to a watch-listed party may not use a general licence or a registration-based certificate, and a single-licence application needs a risk assessment and compliance undertaking. The control list targets violations of end-user/end-use requirements, risks to national security and interests, or use of dual-use items for terrorism; transactions must not violate the rules, and exceptional transactions require an application.
A list check is not "once and forever." Changes in customer structure, shareholders, or end use can trigger re-review; check at least before trading, before signing, and before shipment, and keep the time, checker, and screenshot. Use the authority's published list, not an outdated third-party copy. The website can say "we check the relevant lists before trading," but should not publish a customer's list status.
| List | Trigger | Effect on exports | Common gap |
|---|---|---|---|
| Watch list | Non-cooperation with verification | No general licence/certificate; single licence needs risk assessment and undertaking | Old customer waved through |
| Control list | End-user/use violations, national-security risk, terrorism | No non-compliant transactions; exceptional cases need application | Shipping without knowing |
| Check points | Before trading, signing, shipment | Keep search records | Annual review only |
| Removal | Cooperation and remedial measures | Per authority decision | Self-declared removal |
This summary is editorial; see Articles 26 and 28 of the Regulation and the authority's publications.
How should customs presentation, queries, and amendments be handled?
For dual-use exports, the shipper or customs broker must present the export licence issued by the competent authority and complete customs formalities; without a licence, customs will not release the goods. If customs has evidence that goods may fall within dual-use scope, it will question the shipper, who must provide the contract, performance parameters, main use, and other evidence; during questioning and identification, the goods are not released. "Declare first, supply the licence later" does not work—documents, licence, and goods must line up.
Amendments and returns also follow the licence: a licence has scope, conditions, and validity, and changing the description, model, quantity, or end user may exceed it. Continuing to export beyond scope is not fixed by "an explanatory note." The page should give a pre-customs checklist: is the licence valid, do description and model match, is the end user the same, does the broker know it is a dual-use item, are statements attached.
| Stage | What to do | Evidence | Common gap |
|---|---|---|---|
| Presentation | Present licence, declare per licence | Licence/declaration | Declare without licence |
| Customs query | Provide contract, parameters, main use | Explanation pack | Irrelevant answer |
| Identification | Cooperate; goods not released | Conclusion | Press for release |
| Amendment | Check whether it exceeds the licence | Change record | Amend and forget |
| Return | Handle per licence and customs | Return record | Dispose privately |
| Broker/forwarder | Notify in writing of status and licence | Notice letter | Not told |
Customs requirements are in Articles 21 and 22 of the Regulation and Article 19 of the Export Control Law.
How should transit, transshipment, re-export, and bonded zones be treated?
Do not assume that "the goods never enter China's customs territory" or "it is only a transshipment" takes it outside the regime. Article 45 of the Export Control Law provides that transit, transshipment, through transport, and re-export of controlled items, or export to overseas from customs-special supervision areas such as bonded zones and export processing zones, export supervision warehouses, and bonded logistics centres, are governed by the Law. Goods transiting a Chinese port, stored in a bonded zone and then exported, or imported controlled items re-exported may all require export-control handling.
Article 44 further provides that organisations and individuals outside China that violate the export-control rules, endanger national security and interests, or obstruct non-proliferation obligations are dealt with and held liable under the law. For manufacturers involved in entrepot trade, bonded warehousing, or international logistics, the compliance boundary is not only "the direct export shipment." The page should tell customers: for transit, re-export, or bonded movement, confirm the licence requirement before the goods reach the port.
| Scenario | Export-control handling? | What to confirm | Common gap |
|---|---|---|---|
| Transit/transshipment | Governed by the Law | Item, destination, end user | "Just logistics" |
| Re-export | Governed by the Law | Original import terms, new destination | Resell and ship |
| Bonded/export processing zone | Export overseas governed by the Law | Leaving the zone is export | "Inside the zone is not export" |
| Bonded warehouse/logistics centre | Export overseas governed by the Law | Export after storage | Storage step missed |
| Overseas party violation | Dealt with and held liable | Overseas organisations and individuals | "Beyond reach" |
Scope is in Articles 44 and 45 of the Export Control Law; specific cases follow the authority and customs.
What records should be kept, and for how long?
At minimum: classification and list-comparison records, consultation replies, licence application materials and certificates, end-user and end-use certificates, contracts/invoices/ledgers/vouchers/business correspondence, customs declarations and release records, list search records, exception reports and handling, and training and audit records. Article 27 of the Regulation requires end-user and end-use certificates and related contracts, invoices, ledgers, vouchers, and business correspondence for dual-use exports to be kept for no less than five years, unless other laws or administrative regulations provide otherwise.
Record-keeping is not dumping files on a shared drive. Each shipment should be traceable by customer—contract—licence—customs declaration—end-user statement, retrievable within minutes. Give each shipment a compliance file number, keep paper and electronic copies, and control access; customer information, technical parameters, and licence documents are sensitive and should not sit on a public cloud folder or website download directory.
| Record | Content | Retention | Common gap |
|---|---|---|---|
| Classification | List comparison, parameters, consultation | ≥5 years | No record |
| Licence | Application, certificate, changes | ≥5 years | Number only |
| End user | Original statement, government certification, review | ≥5 years | Scan only |
| Transaction | Contract, invoice, ledger, vouchers, correspondence | ≥5 years | Scattered in mailboxes |
| Customs | Declaration, release, query and identification | ≥5 years | Not findable |
| Lists/exceptions | Search screenshots, reports, handling | ≥5 years | Not recorded |
Retention is in Article 27 of the Regulation; specific filing follows company compliance, customs, and industry rules.
What should the page say, and what must not be published?
A public page should include: a compliance statement (compliance with export-control laws, an ICP in place), the controlled-item screening process, licence-type explanation, end-user statement requirements and a template download, the document list customers must provide, review time and contact, and FAQs. Do not publish: specific licence numbers or scans, technical parameters and classification conclusions, customer and end-user names, the full internal review form, or customs and inspection details. A public template may give "elements," not a completed customer version.
The page exists to tell customers how to cooperate and sales how to start—not to prove "we have no risk." Wording should be restrained: "handled under current laws and regulations" and "subject to the competent authority's determination," not "all our products are uncontrolled" or "release guaranteed." A template download behind a form or email both serves customers and leaves a lead and version record.
| Module | What to write | Evidence/asset | Common gap |
|---|---|---|---|
| Compliance statement | Comply, ICP in place, authority determines | Policy document | Absolute promises |
| Screening process | Model—parameters—use—destination—end user | Flow chart | "Expert team" only |
| Licence explanation | Differences among single/general/certificate | Comparison | Implying general licence for all |
| Statement template | Elements, instructions, submission | Template file | Completed customer version public |
| Document list | What customers provide, review time | Checklist | Endless supplements |
| Boundaries | No licence numbers, parameters, customers, internal forms | Access control | PDF with customer data |
| Links | Documents, product compliance, technical data | Page test | Broken links |
These modules are editorial; public scope, customer data, and wording follow confidentiality requirements and legal advice.
Go-live acceptance checklist
Ten checks: screening process, licence types, statement elements, document verification, internal compliance, list checks, customs handover, transit/re-export notice, retention, and public boundaries/links. Each needs an owner, evidence, and review date. The pass condition is not "the page says we comply," but that a customer can prepare documents from the page, sales can start the review, and customs can check licence and documents against the checklist.
Before go-live, run one real export through: inquiry → item screening → end-user statement → list check → licence decision → customs presentation → exception handling → filing. Any step that fails is a step the page has not explained—and possibly a gap in the internal process that the page only exposes.
| Check | Pass condition | Evidence | If it fails |
|---|---|---|---|
| Screening | List, temporary control, and outside-list risk | Flow chart | Add process |
| Licence types | Single/general/certificate and validity | Comparison | Add explanation |
| Statement | Entity, use, item, undertaking, signature, certification | Template | Revise template |
| Verification | Six checks: entity/use/item/signature/currency/lists | Check form | Add checks |
| ICP | Organisation, classification, review, licence, exception, training, audit | Policy/records | Build policy |
| Lists | Watch/control list timing and records | Screenshots | Add checks |
| Customs | Presentation, query response, amendment check | Declaration | Add handover |
| Transit/re-export | Transit, transshipment, bonded zone, re-export notice | Page | Add section |
| Records | Classification, licence, statement, transaction, customs, exceptions ≥5 years | File | Add filing |
| Boundaries/links | No licence numbers/parameters/customers; documents/compliance/technical pages reachable | Page test | Remove/fix |
This checklist is editorial; specific classification, licensing, customs, and retention follow the law, authority, customs, and company policy.
Who should read this, who should not, and what decisions does it support?
It suits manufacturers in Changzhou and nearby areas with export business, products that may involve dual-use items, customers requesting export-control statements, or an ongoing supply-chain compliance audit—especially equipment, machine tools, electronics, sensors, materials, software, and technical services; it also suits entrepot trade, bonded warehousing, and international logistics. It does not suit domestic-only businesses with no export or technology transfer, or teams wanting one page to replace legal advice.
Read it if you are in export, customs, legal, quality, engineering, sales, or a website vendor; you are building an export-control page, end-user statement template, licence process, list checks, or record system; or you need to answer "does this model need a licence, is the customer statement enough, what if customs queries, how long do we keep records." Skip it if you treat export control as "stamp whatever the customer sends," use an internet template instead of statement elements, or want a page that promises "release guaranteed." It supports self-review of screening, licensing, statements, verification, compliance, customs, records, and public boundaries.
Lingyi Information is a website development and enterprise AI project provider, not a law firm, customs broker, export-control consultancy, or competent authority. This article is not a substitute for legal, export-control, customs, or compliance advice. Changzhou projects are delivered remotely or on site as confirmed per project; Lingyi is one candidate, does not claim a local office or team, and does not promise licence outcomes, release times, conversion, or inquiries.
FAQ
If the product is not on the list, is it exempt?
No. Listed items need a licence; outside the list, if the exporter knows or should know—or is notified—that goods, technology, or services may endanger national security and interests, be used for weapons of mass destruction and their means of delivery, or be used for terrorism, a licence is also required. If uncertain, consult the authority; do not release merely because "it is not listed."
Who issues the end-user statement?
The end user, not the exporter. It should contain entity information, end use, item model and quantity, an undertaking not to change the use or transfer, and an authorised signature and seal; the authority may also require a document issued or certified by the end user's government. The statement must match the contract, invoice, and customs declaration.
What is the difference between a single and a general licence?
A single licence covers one specific export to a single end user and is valid for no more than one year; a general licence covers multiple specific exports to one or more end users and is valid for no more than three years, usually requiring an operating ICP. A registration-based export certificate is handled per shipment. The item, customer, channel, and compliance record decide, and the authority reviews.
What if the customer refuses to provide an end-user statement?
First determine whether a licence or review is required; if it is and the document cannot be provided, do not continue the export. Sales can explain the requirement and provide a template and instructions, and verify the use by video or site visit if needed; if it still cannot be met, escalate under the ICP and, if necessary, decline the deal. A customer's verbal "it is civilian" is not a substitute for a document.
How long must records be kept?
End-user and end-use certificates and related contracts, invoices, ledgers, vouchers, and business correspondence for dual-use exports must be kept for no less than five years, unless other laws or administrative regulations provide otherwise. Index by customer—contract—licence—customs—statement, keep paper and electronic copies, and control access.
Can the website publish licences and customer statements?
Publishing specific licence numbers, scans, customer and end-user information, technical parameters, or classification conclusions is not advisable. Publish the compliance statement, screening process, licence explanation, statement elements template, and contact; give "elements" and instructions, not a completed customer version, and put the download behind a form or email for traceability.
One-sentence takeaway
A Changzhou manufacturer's export-control and end-user statement page should not be one sentence about "complying with the law." It should turn the three screening lines (list, temporary control, outside-list risk), licence types, statement elements, document verification, internal compliance, list checks, customs handover, transit/re-export, five-year retention, and public boundaries into a verifiable checklist—so customers know what to provide, sales knows how to start, and customs knows what to check.
Method and limitations
This is a review of public regulations and project practice, not a compliance certification or legal opinion on any company, product, item classification, licence, end user, or customs declaration. No undisclosed customer lists, licence documents, technical parameters, or customs data were used. The screening process, statement elements, verification form, checklists, and acceptance checklist are editorial suggestions, not legal, export-control, customs, or compliance conclusions. Specific classification, licensing, end-user review, customs handling, and retention depend on the law, authority announcements, customs requirements, and company policy.
Sources and scope
Information is current to 2026-11-02. The following are public official/primary pages; their scope, version, and wording control.
- Export Control Law of the PRC (adopted 17 October 2020, effective 1 December 2020): Ministry of Commerce of the PRC. Control list and temporary control (Art. 9), licensing and outside-list risk (Art. 12), review factors (Art. 13), ICP and general-licence facilitation (Art. 14), end-user and end-use certificates (Art. 15), end-user undertaking and reporting (Art. 16), control list (Art. 18), customs presentation (Art. 19), overseas parties and transit/transshipment/re-export (Arts. 44 and 45).
- Regulation on the Export Control of Dual-Use Items (State Council Order No. 792, effective 1 December 2024): Ministry of Commerce of the PRC. Licence types and validity (Art. 15), application materials (Art. 16), customs presentation and queries (Arts. 21 and 22), end-user and end-use management (Arts. 23–25), watch list (Art. 26), five-year retention (Art. 27), control list (Art. 28).
- Catalogue of Dual-Use Items Subject to Export Control (MOFCOM, MIIT, General Administration of Customs, and State Cryptography Administration Announcement No. 51 of 2024, effective 1 December 2024): Ministry of Commerce of the PRC. List entries and technical parameters follow the announcement annex; whether a specific item is controlled requires item-by-item comparison.