The Eleven Announcements the List Replaced

The consolidated dual-use list took effect on 1 December 2024 and replaced eleven separate announcements in one move. Anyone holding a compliance memo that cites one of those numbers is now citing a repealed instrument, and the replacement is not a straight renumbering: several announcements were broken up and distributed across the list.

What the announcement did

Announcement No. 51 of 2024 was published on 15 November 2024 and took effect on 1 December. Annex 1 is the list itself. Annex 2 names the eleven announcements repealed the same day.

The numbering system changed with it. The old instruments were identified by year and sequence, like Announcement No. 33 of 2024. The list is identified by alphanumeric entry, like 3C003. The entry is where the conditions live, and the entry number is how a later instrument reaches the one it amends: Announcement No. 10 of 2025 amends 1C117.c and 1C117.d by number.

Where each one went

All eleven resolve. Five are single entries: 1C501, 9A501, 8A901, 1C350 item k and 1C108. The other six were split. 2015 No. 31 became 9A012 for its unmanned-aircraft half and 4A003 for its computer half; 2022 No. 31 became 0A901 and 0A902; 2023 No. 23 became 3C001 and 3C002; 2024 No. 21 became five entries plus the software and technology entries that go with them; 2024 No. 31 became 9A012 and 0A903; and 2024 No. 33 became seven.

The 2015 instruments are worth a note. 2015 No. 20 names its subject in its title and controls three classes of military-civil unmanned aircraft; 9A501 carries all three plus the model-aircraft carve-out. 2015 No. 31 does not name its subject: it covers unmanned aircraft and high-performance computers, and its computer half is 4A003, which carries the same processing-speed test.

The three that matter here

Take the gallium and germanium announcement of 2023 first. It is now two entries: 3C001 for gallium, which runs from the metal through the nitride, oxide, phosphide, arsenide, indium gallium arsenide, gallium selenide and antimonide, and 3C002 for germanium, six items from metal through zone-refined ingot, zinc germanium phosphide, epitaxial substrates, dioxide and tetrachloride. Neither carries a purity threshold. The gallium guide and the germanium guide work through what each entry catches.

The antimony announcement of 2024 became 3C003, and that entry does carry thresholds, where a single figure would have done. Its oxide line is the one that surprises buyers: 99.99% and above, while the four grades Amspec lists carry minimum total Sb2O3 of 99.5% (KR and LTS), 99.8% (Select) and 99.9% (SP), all in typical-composition tables. The same announcement carried a second half on superhard materials, which went to 2A901 for the press components, 2B005 for MPCVD equipment, 2B901 for the cubic press itself, 2C901 for diamond window material and 2E901 for the process technologies, with the gold-antimony separation technology at 3E003. The antimony page sets out what the oxide threshold decides.

Graphite is the third, at 1C108. It is not a material this site covers, and it is in the table because a reader comparing old and new citations will meet it.

Why the mapping is worth keeping

A repeal is not a repeal of the subject. The liability described in Announcement No. 33 of 2024 did not disappear on 1 December; it moved into the list, with the oxide threshold unchanged in 3C003. What did disappear is the document. A supplier’s confirmation letter that cites the old number points at a document that no longer carries an operative condition.

There is a second pattern worth knowing. The list is a living document, and each revision arrives as its own instrument. Announcement No. 10 of 2025, on tungsten and four other elements, closes with the sentence 本公告自发布之日起正式实施。《中华人民共和国两用物项出口管制清单》同步予以更新: the announcement takes effect on publication and the list is updated in step. That sentence tells a reader the list was revised. It does not tell them what the revision says, so a reader has to track the list edition and the announcements that amend it, and the amendment text may differ from the entry it amends. One worked example of that divergence is in the note on 1C117.c.

What to do with a memo

Three checks, in order.

1. Does the memo cite an announcement number or a list entry? If it cites a number from the eleven above, the citation is stale.
2. If it cites an entry, does it say which edition of the list? The list has been amended since 1 December 2024.
3. Does the memo quote the operative condition, or only the entry number? An entry can carry several tests that must all be met, and a memo that names the entry without the tests is not a determination.

Methodology

Annex 2 to Announcement No. 51 of 2024 is the source for the eleven repealed announcements and their titles; where a title names no subject, the subject comes from the instrument itself. Entry numbers were found by searching Annex 1 for the subject of each repealed announcement, then reading the entry. That method has a blind spot worth stating: two destinations do not carry their subject in the entry heading. 0A902 is titled only by reference to 0A901, and 2E901 is titled 以下技术, with the press and the synthesis process named in its sub-items. Both were missed on the first pass and found by reading the entries around the one already identified. Each of the eleven instruments appears in the Sources list, so a row can be checked against the instrument itself; the two 2015 texts sit on MOFCOM’s legal database rather than its news channel. Entry contents for 1C501, 9A501, 8A901, 1C350, 1C108, 3C001, 3C002, 3C003, 3E003, 2A901, 2B005, 2B901, 2C901, 2E901, 0A901, 0A902, 9A012, 0A903, 1B003, 9B001, 9B004, 0B901, 1C901 and 4A003 were read in the original, as were the full texts of Announcements No. 33, No. 21 and No. 31 of 2024. The oxide grades come from the producer’s published typical-composition tables, not from any instrument. The closing sentence of Announcement No. 10 of 2025 is quoted as published, and nothing here depends on a version of the list that postdates the ones cited.

Sources

商务部、海关总署公告 2003 年第 5 号，关于对磷酸三丁酯实施临时出口管制的公告。 https://www.mofcom.gov.cn/zcfb/blgg/art/2005/art_1a3989e32fc1421fa548ae840b09a59e.html

商务部、海关总署、国防科工局、总装备部公告 2015 年第 20 号，关于对军民两用无人驾驶航空飞行器实施临时出口管制措施的公告，2015-06-25。 https://policy.mofcom.gov.cn/claw/clawContent.shtml?id=49425

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商务部、海关总署公告 2017 年第 28 号，关于对挖泥船实施出口管制的公告，2017-05-25。商务部未提供原文页，以下为山东省商务厅转载。 http://commerce.shandong.gov.cn/art/2017/6/2/art_16087_1705767.html

商务部、海关总署公告 2021 年第 46 号，关于对高氯酸钾实施出口管制的公告。 https://www.mofcom.gov.cn/zcfb/blgg/art/2021/art_3c25922d284a4ea1a1c873eec829dac7.html

商务部、海关总署、国家国防科技工业局公告 2022 年第 31 号，关于对高压水炮类产品实施出口管制的公告。 https://www.mofcom.gov.cn/zcfb/blgg/art/2022/art_7c389f6b8b22434b93f08ea4ba2b643b.html

商务部、海关总署公告 2023 年第 23 号，关于对镓、锗相关物项实施出口管制的公告。 https://www.mofcom.gov.cn/zcfb/dwmygl/art/2023/art_52b9a321087f402bb3d310d18b07967e.html

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商务部、工业和信息化部、海关总署、国家密码局公告 2024 年第 51 号，《两用物项出口管制清单》附件 1 与附件 2，2024-12-01 施行。 https://www.mofcom.gov.cn/zcfb/dwmygl/art/2024/art_e56833e346534981b250bae772d0cbce.html

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商务部、海关总署公告 2025 年第 10 号，对钨、碲、铋、钼、铟相关物项实施出口管制，2025-02-04。 https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_e623090907fc4e1092f0a4db72f57b95.html

Amspec Chemical, KR antimony trioxide grade, typical chemical composition: minimum total Sb2O3 99.5%, arsenic 0.10%, lead 0.10%. https://www.amspec.net/products/flame-retardants/kr-antimony-trioxide/

Amspec Chemical, Select antimony trioxide grade. https://www.amspec.net/products/flame-retardants/select-antimony-trioxide/