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China Tightens Export Controls on Tunnel Boring Machines, Walking Excavators, and High-Altitude Wet Sprayers

China’s MOFCOM and GAC Announce Export Controls on Key Construction Equipment Effective November 18, 2026 — What Foreign Founders Need to Know

New Export Control Regime for Advanced 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 certain tunnel boring machines, walking excavators, and high-altitude wet sprayers. The measures, approved by the State Council, take effect on November 18, 2026, and are grounded in China’s Export Control Law, Foreign Trade Law, Customs Law, and Regulations on Export Control of Dual-Use Items. For foreign founders operating manufacturing, construction equipment, or technology companies in China, these controls affect export planning and compliance obligations.

Controlled Items: Tunnel Boring Machines and Components

The announcement lists several categories of controlled goods. Under heading 2B906, full-face tunnel boring machines are covered, including earth pressure balance shield machines, slurry shield machines, and other shield machines (HS code 8430313010), as well as open-type, single-shield, double-shield rock tunnel boring machines and other rock TBMs (HS code 8430313010).

Heading 2A906 captures parts specially designed for the above machines: cutter heads (HS code 8431499910), screw conveyors (HS code 8428310010), segment erectors (HS code 8479899959), and main drive systems and other key units (HS code 8431499910). Heading 2E906 covers remanufacturing technology specially designed for goods controlled under 2A906 or 2B906.

Walking Excavators and Related Technology

Under 2B904, walking excavators with any of the following characteristics are controlled (HS code 8429521920): ability to cross vertical obstacles exceeding 1.2 m; wading depth over 1.5 m; trench-crossing width over 3 m; or walking gradeability over 40 degrees. The technical note defines a walking excavator as machinery that uses combined actions of working equipment, outriggers, or wheels to achieve self-propulsion for multifunctional digging across all terrains. Heading 2E904 covers electro-hydraulic proportional control technology for hydraulic systems specially designed for 2B904 items.

High-Altitude Wet Sprayers and Components

Heading 2B903 controls high-altitude wet sprayers for use above 3,000 m that meet all of the following: engine maximum power over 75 kW and torque over 680 N·m; motor maximum power over 55 kW; pumping system suction efficiency above 95%; air compressor displacement over 15 m³/min; and low-temperature hydraulic oil usable at -20°C (HS code 8479109010). A technical note defines high-altitude wet sprayers as equipment that transports mixed materials (such as concrete) to a nozzle and sprays them onto the working surface by adding air and accelerating agents.

Heading 2A903 covers parts specially designed for 2B903 items: high-altitude engines with max power over 75 kW and torque over 680 N·m (HS codes 8408909240, 8408909330); engine auxiliary oxygen supply devices (HS code 8421399030); high-altitude motors with max power over 55 kW (HS codes 8501520020, 8501530020); two-stage air compressors with displacement over 15 m³/min (HS code 8414804110); high-altitude chassis (HS code 8479909030); and folding arms (HS code 8479909030). Heading 2E903 covers hydraulic and pumping technology specially designed for 2B903 items.

Licensing and Export Procedures

Exporters shipping these items to sensitive countries and regions that have disputes with China must apply to the State Council’s commerce department for permission under the Export Control Law and the Dual-Use Items Regulations. Without a license, no exports to those destinations are allowed. For exports to other countries and regions worldwide, exporters must obtain an export voucher by registering and filing information. Both the exporter and the end user must commit that, without authorization, they will not transfer or provide China-origin controlled items to countries or regions with 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 and Compliance Obligations

Exporters are responsible for the authenticity of declared goods and must strengthen identification of export items. If an item is controlled, the customs declaration must note “dual-use item” in the remarks column and list the dual-use export control code. If an item is not controlled but its parameters, indicators, or performance are close to controlled thresholds, the declaration must note “not a controlled item” and provide specific parameters and indicators. Customs will question declarations where the completeness, accuracy, or authenticity of information is in doubt, and goods will not be released during the questioning period.

Implications for Foreign Founders

Foreign founders with Chinese-based operations in construction equipment, mining, or infrastructure supply chains should review product portfolios and technical specifications against the new control lists. Export transactions involving the listed goods and technologies will require either licenses or registration-based vouchers, and end-user commitments must be obtained. Compliance procedures for customs declarations should be updated to ensure accurate classification and remarks. The control list is effective November 18, 2026, and the Dual-Use Items Export Control List has been updated accordingly.

This summary is based on information published by the relevant Chinese government website and is general information, not legal or tax advice.

For assistance with company registration and operations in China, foreign founders can contact ChinaMNC on WhatsApp / WeChat at +86 153 1898 8535.