Published by ChinaMNC · Luxi
China Adds Tunnel Boring Machines, Walking Excavators and High-Altitude Wet Shotcrete Machines to Export Control List
Foreign founders whose China-based companies make, trade or re-export tunnel boring machines, walking excavators or high-altitude wet shotcrete machines and their parts should review licensing and customs declaration duties under MOFCOM/GAC Announcement No. 50 of 2026, effective 18 November 2026.
What the Announcement Does
China's Ministry of Commerce (MOFCOM) and the General Administration of Customs (GAC) have issued Announcement No. 50 of 2026, published on 19 October 2026 by the Bureau of Security and Control. Citing the Export Control Law, the Foreign Trade Law, the Customs Law and the Regulations on Export Control of Dual-Use Items, and with State Council approval, the announcement places three categories of construction equipment and related items under export control to safeguard national security and interests.
The controls take effect on 18 November 2026, and the consolidated dual-use export control list is updated at the same time. For a foreign founder running a China-based manufacturing, trading or leasing company in this equipment space, the announcement is principally a licensing and customs-declaration compliance matter rather than a company-registration matter — but it must be built into how the entity is set up and operated.
The Controlled Items
Tunnel boring machines and components
- 2B906: full-face tunnel boring machines, including earth-pressure-balance shield machines, slurry shield machines and other shield types, plus open-type, single-shield, double-shield and other rock tunnel boring machines (reference customs codes 8430313010).
- 2A906: parts specially designed for 2B906 items — cutter heads (8431499910), screw conveyors (8428310010), segment erectors (8479899959) and main drive systems and other key units (8431499910).
- 2E906: remanufacturing technology specially designed for 2A906 or 2B906 items.
Walking excavators
- 2B904: walking excavators meeting any one of these thresholds: crossing vertical obstacles above 1.2 m; wading depth above 1.5 m; crossing trenches wider than 3 m; or climbing gradients above 40 degrees (8429521920). The announcement defines a walking excavator as machinery that uses combined movements of its working equipment, outriggers or wheels to move itself and perform multi-function excavation across general terrain.
- 2E904: electro-hydraulic proportional control technology for hydraulic systems specially designed for 2B904 items.
High-altitude wet shotcrete machines
- 2B903: machines for use above 3,000 m altitude that meet all of the following: engine maximum power above 75 kW and torque above 680 N·m; motor maximum power above 55 kW; pumping system suction efficiency above 95%; air compressor displacement above 15 m³/min; and low-temperature hydraulic oil usable at -20°C (8479109010).
- 2A903: specially designed parts, including high-altitude engines above 75 kW/680 N·m (8408909240, 8408909330), engine auxiliary oxygen supply devices (8421399030), high-altitude motors above 55 kW (8501520020, 8501530020), two-stage compressors above 15 m³/min (8414804110), high-altitude chassis (8479909030) and folding arms (8479909030).
- 2E903: hydraulic and pumping technology specially designed for 2B903 items.
Licensing Rules: Two Destinations, Two Procedures
Exports to sensitive countries and regions with which China has disputes require an application to the State Council's commerce authority for a licence under the Export Control Law and the dual-use regulations. No export may proceed without a licence.
Exports to all other destinations follow a different route: the exporter obtains an export voucher by registering and filing the required information. Both the exporter and the end user must undertake not to transfer or provide China-origin controlled items to sensitive countries and regions with which China has disputes without a licence. Organisations and individuals outside China are also barred, without a licence, from transferring or providing such China-origin items to those sensitive destinations.
Customs Declarations and Documentation
Exporters are responsible for the truthfulness of declared goods and must strengthen identification of export items. Where goods are controlled, the remarks column of the customs declaration must state that they are dual-use items and list the dual-use export control code. Where goods are not controlled but their parameters, indicators or performance are close to the thresholds, the remarks column must state that they are not controlled and set out the specific parameters and indicators.
Where customs has doubts about the completeness, accuracy or truthfulness of the filed information, it will raise a query under law, and the goods will not be released while the query is pending.
What This Means for Your China Entity
Scope your business licence and filings. If your China company manufactures, trades, leases or re-exports any of these machines, parts or technologies, confirm that its registered business scope and internal product classifications cover the activity. Product classification should be documented before the first shipment after 18 November 2026.
Build compliance into operations. Registration alone does not authorise exports. Maintain records mapping each product to the relevant control code, keep end-user undertakings on file, and train staff who prepare customs declarations, since the remarks-column requirements are mandatory and errors can halt release of goods.
Review contracts and counterparties. Sales, distribution and technology-licensing agreements should reflect the licensing and no-transfer undertakings, particularly where end users or intermediaries are located outside China.
Check related items. Components such as cutter heads, screw conveyors, segment erectors, main drives, high-altitude engines and motors, oxygen supply devices, compressors, chassis and folding arms fall within scope when specially designed for controlled machines, so procurement and sales teams should screen parts as well as finished equipment.
Plan for timing. The rules apply from 18 November 2026, alongside the updated dual-use control list. Companies with pending orders should assess whether licences or registration filings are needed before shipment.
Next Steps for Founders
Foreign founders should treat this announcement as part of the compliance architecture around their China entity: correct business scope, accurate product classification, documented end-user commitments and disciplined customs declarations. Because the announcement distinguishes between licensed destinations and registration-based destinations, the destination of each shipment should be verified before contracting.
This summary is based on information published by the relevant Chinese government website and is general information, not legal or tax advice.
Foreign founders can contact ChinaMNC on WhatsApp / WeChat at +86 153 1898 8535 for help registering and operating a company in China.