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China Adds Tunneling Machines, Walking Excavators, and High-Altitude Sprayers to Export Control List

China's MOFCOM and Customs announced export controls on tunnel boring machines, walking excavators, and high-altitude wet spraying machines, effective November 18, 2026. Foreign founders in China must comply with licensing and registration requirements.

Foreign founders operating in China’s construction equipment, infrastructure, or manufacturing sectors should note that China’s Ministry of Commerce (MOFCOM) and General Administration of Customs have issued Announcement No. 50 of 2026, imposing export controls on certain dual-use items including tunnel boring machines, walking excavators, and high-altitude wet spraying machines. The measure, approved by the State Council and based on China’s Export Control Law, Foreign Trade Law, Customs Law, and Dual-Use Items Export Control Regulations, takes effect on November 18, 2026. The announcement is aimed at safeguarding national security and interests.

What Items Are Now Controlled?

The controls cover three main categories of equipment and related parts and technologies. Foreign founders whose companies manufacture, trade, or use such items should carefully review whether their products fall under the listed control codes.

1. Tunnel Boring Machines and Related Items

• 2B906 – Full-face tunnel boring machines: Includes earth pressure balance shield machines, slurry shield machines, and other types of shield machines (HS code reference: 8430313010); and open-type, single-shield, double-shield rock tunnel boring machines and other rock TBMs (HS code reference: 8430313010).
• 2A906 – Parts specially designed for 2B906 items: Includes cutter heads (HS code reference: 8431499910); screw conveyors (HS code reference: 8428310010); segment erectors (HS code reference: 8479899959); and main drive systems and other key units (HS code reference: 8431499910).
• 2E906 – Remanufacturing technology specially designed for 2A906 or 2B906 items.

2. Walking Excavators and Related Items

• 2B904 – Walking excavators with any of the following characteristics (HS code reference: 8429521920): climbing vertical obstacles over 1.2 m; wading depth over 1.5 m; crossing trenches wider than 3 m; or walking gradeability over 40°.
• 2E904 – Electro-hydraulic proportional control technology for hydraulic systems specially designed for 2B904 items.

Technical note: A walking excavator is defined as mechanical equipment that uses combined actions of working devices, outriggers, or wheels to achieve self-propulsion for multifunctional excavation across all-terrain conditions.

3. High-Altitude Wet Spraying Machines and Related Items

• 2B903 – High-altitude wet spraying machines for use above 3,000 m altitude with all of the following characteristics (HS code reference: 8479109010): 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.
• 2A903 – Parts specially designed for 2B903 items: high-altitude engines with max power over 75 kW and torque over 680 N·m (HS code reference: 8408909240, 8408909330); engine auxiliary oxygen supply devices (HS code reference: 8421399030); high-altitude motors with max power over 55 kW (HS code reference: 8501520020, 8501530020); two-stage air compressors with displacement over 15 m³/min (HS code reference: 8414804110); high-altitude chassis (HS code reference: 8479909030); and folding arms (HS code reference: 8479909030).
• 2E903 – Hydraulic and pumping technology specially designed for 2B903 items.

Technical note: A high-altitude wet spraying machine is equipment that transports mixed materials (such as concrete) to a nozzle in high-altitude areas, adds air and accelerator, and sprays the material onto the working surface.

Export Licensing and Registration Requirements

Exporters shipping the above items to sensitive countries and regions that have disputes with China must apply for a license from the State Council’s commerce department in accordance with the Export Control Law and Dual-Use Items Export Control Regulations. Without a license, exports to such countries and regions are prohibited.

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 Chinese-origin items to countries and regions that have disputes with China. Organizations and individuals outside China are also prohibited from transferring or providing Chinese-origin 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 identification of export items. For items that are controlled, the customs declaration remarks column must state “dual-use item” and list the dual-use export control code. For items that are not controlled but have parameters, indicators, or performance close to controlled items, the remarks column must state “not a controlled item” and fill in specific parameters and indicators. If customs has doubts about the completeness, accuracy, or authenticity of the declared information, it will raise queries in accordance with the law, and the goods will not be released during the query period.

Implications for Foreign Founders

Foreign founders with companies in China that manufacture, trade, or use these types of construction equipment should assess whether their products or technologies fall under the control list. If they do, they must establish internal compliance procedures to ensure proper licensing and customs declaration. The controls also affect re-export and transfer activities, so companies should train staff and update contracts with end users. Given the effective date of November 18, 2026, now is the time to review supply chains and customer bases.

For assistance with company registration, compliance, or operational matters 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.