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China’s New Export Controls on Tunnel Boring Machines, Walking Excavators and Plateau Wet Shotcrete Machines: What Foreign Founders Need to Know

China’s Ministry of Commerce and General Administration of Customs Announcement No. 50 of 2026 imposes export controls on tunnel boring machines, walking excavators, and plateau wet shotcrete machines, effective November 18, 2026. Foreign founders operating in China must understand licensing, registration, and customs compliance obligations.

Overview of the New Export Control Measures

On October 19, 2026, China’s Ministry of Commerce (MOFCOM) and the General Administration of Customs issued Announcement No. 50 of 2026, introducing export controls on certain equipment related to tunnel boring machines, walking excavators, and plateau wet shotcrete machines. The measures are based on the Export Control Law, the Foreign Trade Law, the Customs Law, and the Regulations on Export Control of Dual-Use Items. They take effect on November 18, 2026, and the Dual-Use Items Export Control List will be updated accordingly.

For foreign founders with companies in China that manufacture, trade, or export construction or mining equipment, these controls affect export planning and compliance procedures. Understanding the scope and obligations is essential to avoid shipment delays or legal risks.

Controlled Items and Technical Parameters

The announcement covers three categories of goods, each with specific technical thresholds and control codes.

1. Tunnel Boring Machines and Related Parts (Control Codes 2B906, 2A906, 2E906)

Complete tunnel boring machines are controlled, including earth pressure balance shield machines, slurry shield machines, and other shield machines, as well as open-type, single-shield, double-shield rock tunnel boring machines and other rock TBMs (HS code reference: 8430313010).

Parts specially designed for these machines are also controlled: cutter heads (HS 8431499910), screw conveyors (HS 8428310010), segment erectors (HS 8479899959), and main drive systems and other key units (HS 8431499910). Remanufacturing technology specially designed for these controlled items falls under control code 2E906.

2. Walking Excavators (Control Codes 2B904, 2E904)

Walking excavators (HS 8429521920) are controlled if they meet any of the following characteristics: ability to cross vertical obstacles over 1.2 m; wading depth over 1.5 m; trench-crossing width over 3 m; or climbing gradient over 40°. The announcement defines a walking excavator as machinery that uses combined actions of working equipment, outriggers, or wheels to achieve self-propulsion for multi-functional excavation on all-terrain surfaces.

Hydraulic system electro-hydraulic proportional control technology specially designed for these excavators is controlled under 2E904.

3. Plateau Wet Shotcrete Machines (Control Codes 2B903, 2A903, 2E903)

Plateau wet shotcrete machines (HS 8479109010) for use above 3,000 m altitude are controlled if they 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.

Parts specially designed for these machines are controlled under 2A903, including plateau-type engines over 75 kW and 680 N·m (HS 8408909240, 8408909330), engine auxiliary oxygen supply devices (HS 8421399030), plateau-type motors over 55 kW (HS 8501520020, 8501530020), two-stage air compressors over 15 m³/min (HS 8414804110), plateau-type chassis (HS 8479909030), and folding arms (HS 8479909030). Hydraulic and pumping technology specially designed for these machines is controlled under 2E903.

Licensing and Export Procedures

Exporters intending to ship any controlled items to sensitive countries and regions with which China has disputes must apply to the competent commerce department of the State Council for a license under the Export Control Law and the Dual-Use Items Export Control Regulations. Without a license, such exports are prohibited.

For exports to other countries and regions worldwide, exporters must obtain an export certificate by registering and filling in information. The exporter and the end user must commit that, without a license, they will not transfer or provide the China-origin controlled items to countries and regions with which China has disputes. Organizations and individuals outside China are also prohibited from transferring or providing China-origin controlled items to such sensitive countries and regions without a license.

Customs Declaration Obligations

Exporters are responsible for the authenticity of declared goods and must strengthen the identification of export items. If an item is controlled, the remark column of the customs declaration must state “属于两用物项” (dual-use item) and list the dual-use export control code. If an item is not controlled but its parameters, indicators, or performance are close to the thresholds, the remark column must state “不属于管制物项” (not a controlled item) and provide the specific parameters and indicators.

Where customs has doubts about the completeness, accuracy, or authenticity of the declared information, it will raise a query in accordance with the law. During the query period, the export goods will not be released.

Practical Implications for Foreign Founders

Foreign founders with manufacturing or trading operations in China should review their product portfolios against the control lists. Companies producing or exporting tunnel boring machines, walking excavators, or plateau wet shotcrete machines—and their specially designed parts and technologies—must establish internal compliance procedures to classify items correctly, obtain necessary licenses or registration certificates, and ensure accurate customs declarations.

Export contracts should include commitments from end users regarding non-transfer to sensitive countries and regions. Training staff on the new declaration requirements and maintaining documentation of technical parameters will help avoid customs delays.

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.