Assess PRC export controls (MOFCOM)
assess_china_export_controlsAssess whether a transaction triggers Chinese export controls under MOFCOM announcements, accounting for suspensions, rare-earth thresholds, and foreign-party licence duties.
Instructions
Identify Chinese export-control exposure under the Export Control Law, the 2024 Regulations on Export Control of Dual-Use Items, and the numbered MOFCOM announcements. Answers the question that decides most cases in this regime first: is the measure currently in force? Announcements Nos. 55, 56, 57, 58, 61 and 62 of 2025 are suspended by Announcement No. 70 of 2025 until 10 November 2026, while Announcement No. 18 of 2025 on seven medium and heavy rare earths is NOT suspended and still requires a licence. No. 61 has split commencement dates: its Chinese-origin limb began on 9 October 2025, while its content and technology limbs were due on 1 December 2025. A fact pattern that meets a suspended test is reported as license_required_if_reactivated with the expiry date, because the instruments are not repealed. This regime binds non-Chinese parties directly: Announcement No. 61 requires a MOFCOM permit for a shipment between two points both outside China, on a 0.1 percent content floor, and a 管控名单 designation prohibits parties in ANY country from supplying the listed entity with Chinese-origin dual-use items. Do not carry a U.S. de minimis conclusion across; § 734.4 is a 25 or 10 percent ceiling you fall below to escape, while No. 61 is a 0.1 percent floor you rise above to be caught. This tool does NOT classify items and does NOT screen entities, because neither the Export Control List for Dual-Use Items nor any designation list is bundled.
Input Schema
| Name | Required | Description | Default |
|---|---|---|---|
| asOfDate | No | ISO date to assess against, e.g. 2026-12-01. Defaults to today. Decides whether a suspended measure is operative. | |
| itemCategory | No | unknown | |
| endUserMilitary | No | No. 61 § 2: applications for foreign military users are in principle not permitted. | |
| exportToCountry | No | ||
| itemDescription | No | Free-text item description. Scanned for the controlled rare-earth elements, in English or Chinese. | |
| itemOriginChina | No | Whether the item was originally produced in China. No. 61 § 1(c). | |
| counterpartyNames | No | ||
| exportFromCountry | No | ||
| rareEarthElements | No | Rare-earth elements present, e.g. ['dysprosium','terbium']. | |
| chineseRareEarthTechnologyTypes | No | ||
| containsChineseOriginRareEarths | No | ||
| chineseOriginRareEarthValuePercent | No | Value of Chinese-origin rare earths as a percentage of item value. The No. 61 § 1(a) threshold is a 0.1 percent FLOOR, not a ceiling: 0.1 or more is caught. | |
| counterpartyIsSubsidiaryOfListedEntity | No | Whether a parent controlling 50 percent or more of shares is a listed user. No. 61 § 2 reaches such subsidiaries. | |
| producedOutsideChinaUsingChineseRareEarthTechnology | No | No. 61 § 1(b). The Chinese analogue of the Foreign Direct Product rules, with no percentage test. |