China’s Export Control of Dual Use Items: From Multilateralism to Extraterritoriality

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.