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China Tightens Export Controls on Tunnel Boring Machines, Walking Excavators, and High-Altitude Wet Shotcrete Machines
Foreign founders operating in China should note new export control measures effective November 18, 2026, covering tunnel boring machines, walking excavators, and high-altitude wet shotcrete machines, with licensing requirements for sensitive destinations and registration for others.
New Export Control Measures for Construction Equipment
On October 19, 2026, China's Ministry of Commerce (MOFCOM) and General Administration of Customs (GAC) issued Announcement No. 50 of 2026, imposing export controls on specified items related to tunnel boring machines, walking excavators, and high-altitude wet shotcrete machines. The measures, approved by the State Council and based on the Export Control Law, Foreign Trade Law, Customs Law, and Regulations on Export Control of Dual-Use Items, take effect on November 18, 2026. The Dual-Use Items Export Control List has been updated accordingly.
For foreign founders whose companies manufacture, trade, or use such equipment in China, understanding these controls is essential to avoid compliance risks. This article summarizes the key points from the official announcement.
Controlled Items and Technical Specifications
The announcement identifies three categories of controlled items, each with specific technical parameters and reference customs commodity numbers.
1. Tunnel Boring Machines (TBMs) and Related Items
Under control number 2B906, full-face tunnel boring machines are covered, including earth pressure balance shield machines, slurry shield machines, and other types of shield machines (reference HS: 8430313010), as well as open-type, single-shield, double-shield rock tunnel boring machines and other rock TBMs (reference HS: 8430313010).
Additionally, control number 2A906 covers parts specially designed for the above TBMs: cutterheads (HS: 8431499910), screw conveyors (HS: 8428310010), segment erectors (HS: 8479899959), and main drive systems and other key units (HS: 8431499910). Control number 2E906 covers remanufacturing technologies specially designed for the controlled TBMs or their parts.
2. Walking Excavators
Control number 2B904 applies to walking excavators (HS: 8429521920) that meet any of the following characteristics: ability to cross vertical obstacles exceeding 1.2 meters; wading depth exceeding 1.5 meters; ability to cross trenches wider than 3 meters; or walking gradient exceeding 40 degrees. A technical note defines a walking excavator as machinery that uses combined actions of its working device, legs, or wheels to achieve self-propulsion for multifunctional excavation on all-terrain surfaces.
Control number 2E904 covers electro-hydraulic proportional control technologies for hydraulic systems specially designed for such walking excavators.
3. High-Altitude Wet Shotcrete Machines
Control number 2B903 covers high-altitude wet shotcrete machines (HS: 8479109010) for use above 3,000 meters altitude that possess all of the following: engine maximum power exceeding 75 kW and torque exceeding 680 N·m; motor maximum power exceeding 55 kW; pumping system suction efficiency above 95%; air compressor displacement exceeding 15 m³/min; and low-temperature hydraulic oil usable at -20°C. A technical note describes these machines as equipment that transports mixed materials (such as concrete) to a nozzle and sprays them onto a working surface by adding air and accelerator.
Control number 2A903 covers parts specially designed for these machines: high-altitude engines with maximum power over 75 kW and torque over 680 N·m (HS: 8408909240, 8408909330); engine auxiliary oxygen supply devices (HS: 8421399030); high-altitude motors with maximum power over 55 kW (HS: 8501520020, 8501530020); two-stage air compressors with displacement over 15 m³/min (HS: 8414804110); high-altitude chassis (HS: 8479909030); and folding arms (HS: 8479909030). Control number 2E903 covers hydraulic and pumping technologies specially designed for the controlled machines.
Licensing and Registration Requirements
Exporters intending to ship the controlled items to sensitive countries and regions that have disputes with China must apply for a license from the competent commerce department of the State Council under the Export Control Law and the Dual-Use Items Regulations. Without a license, no export to such destinations is permitted.
For exports to other countries and regions worldwide, exporters must obtain an export voucher by registering and filling in the required information. Both the exporter and the end user must commit that, without a license, they will not transfer or provide the China-origin controlled items to sensitive countries and regions that have disputes with China. Organizations and individuals outside China are also prohibited from transferring or providing China-origin controlled items to such sensitive destinations without a license.
Customs Declaration Obligations
Exporters are responsible for the authenticity of customs declarations and must strengthen the identification of export items. For items that fall under export control, the remark column of the customs declaration must state "belongs to dual-use items" and include the dual-use item export control code. For items that are not controlled but whose parameters, indicators, or performance are close to those of controlled items, the remark column must state "does not belong to dual-use items" and provide specific parameters and indicators. If customs has doubts about the completeness, accuracy, or authenticity of the declared information, it will raise queries according to law, and the goods will not be released during the query period.
Implications for Foreign Founders
Foreign founders with companies in China that produce, trade, or use these types of construction equipment should review their product portfolios and supply chains against the technical specifications. If your products are covered, you must follow the licensing or registration procedures for exports. Even if your products are not controlled, if their parameters are close to the thresholds, you must make the appropriate declaration. Non-compliance can lead to delays, penalties, or legal consequences.
Given the complexities, it is advisable to seek professional advice and establish internal compliance mechanisms. ChinaMNC can assist foreign founders with company registration, regulatory compliance, and operational support in China.
Call to Action: For assistance with registering and operating a company in China, foreign founders can contact ChinaMNC on WhatsApp / WeChat at +86 153 1898 8535.
This summary is based on information published by the relevant Chinese government website and is general information, not legal or tax advice.