On 13 October 2026 the Ministry of Commerce Industry Security and Export Control Bureau published a Q&A on the draft Measures for the Administration of Export Certificates for Dual-Use Items Related to the Civil Aviation Field, which are open for public comment.
The draft implements for the first time the export-certificate (registration-and-filing) pathway created by the December 2024 Dual-Use Items Export Control Regulations, allowing qualifying entities to obtain certificates automatically for engines, inertial navigation instruments and similar dual-use items used in outbound maintenance, spares, leasing and related low-risk scenarios in place of per-shipment licenses. Post-export reporting duties and revocation powers are retained.
Who this affects
- For exporters: Domestic airlines (including cargo), foreign airlines, aircraft maintenance enterprises, specialized aviation-material import/export firms with annual turnover above 20 billion yuan, and aircraft and related-item manufacturers may register for automatic certificates covering outbound repair/maintenance/replacement/return of damaged items, inbound repair and bonded-zone returns, and reasonable quantities of spares by domestically headquartered manufacturers.
- For investors: Registration for low-risk scenarios enables paperless customs clearance that shortens civil aircraft parts supply cycles, supports civil-aviation industry internationalization and enhances competitiveness of related services.
- For counsel/compliance: Scope is limited to defined entities and uses; exporters must report certificate use and anomalies, retain documents, and face authority to demand supplemental materials on suspicious exports or revoke certificates in special cases, with administrative penalties refined by reference to the Export Control Law and Dual-Use Regulations.
- For policymakers: First operationalization of the certificate system under the 2024 Regulations, coordinating with the Civil Aviation Administration of China and Customs to limit abuse while facilitating compliant flows.
The read
This is the initial sector-specific application of the registration-based certificate mechanism introduced by the 2024 Dual-Use Regulations, replacing the 2006 annual license-batch approach for civil-aviation dual-use flows. By confining the automatic path to enumerated low-risk maintenance, spares and leasing scenarios while embedding reporting, anomaly obligations and revocation authority, the draft establishes a graded-management template that can be extended to other dual-use categories once comments are incorporated and the measures are finalized.
What was the action?
Public release of the Q&A and solicitation of comments on the 22-article draft Measures that introduce automatic export certificates obtained by registration and filing for specified civil-aviation dual-use items and uses.
What’s the penalty / scope, and how is it set?
No monetary penalty is stated. The draft creates a registration path that replaces per-shipment licenses for qualifying entities and low-risk scenarios (outbound/inbound maintenance, replacement, returns, reasonable spares, and by reference drone exports for overseas exhibition, demonstration or international emergency rescue), while imposing post-export reporting, document-retention duties and authority to require supplemental materials or revoke certificates in special cases; administrative penalties are detailed by reference to the Export Control Law and Dual-Use Items Export Control Regulations.
Who else is exposed?
Not specified in the record beyond the listed entity categories and scenarios; foreign airlines, maintenance enterprises and manufacturers participating in Chinese civil-aviation support chains fall within the draft’s stated scope.
What happens next
MOFCOM will refine the Measures based on public-comment feedback and promote their prompt issuance to facilitate compliant exports by aviation enterprises. No consultation end-date is stated in the Q&A.