China’s 2024
regulation on export control of dual use items led to a transformation from a
fragmented and sector-specific management to a centralized and systemic
governance of export controls. This regulation, which is focused on national
security broadly defined, established a comprehensive regulatory framework with
centralized coordination and multilayered risk prevention mechanisms. Most
importantly, the newly adopted rules provide for extraterritorial enforcement
of export controls, which enhances China’s influence over global supply chains.
In contrast to the European Union and the United States, China employs a ‘few
but precise’ item selection strategy, with particular focus on advanced
technologies and critical raw materials. This disparity between unilateral
export control systems results in asymmetrical regulations, posing new
challenges for corporate compliance and cross-border supply chain management.