Do export controls rules apply to a manufacturer?
Short answer
Yes for production in China of controlled or dual use items. The licence sits with the exporter of record.
Read against the registers 2026-08-26.
Who the role is
Whoever makes the product, or puts a name or trademark on it, carries the first line of product duties.
What the topic covers
China controls what leaves the country by item and by end use. The EU side in our register is the market access and surveillance layer that the same goods meet on arrival.
Duties the EU acts name for this role
- Market Surveillance Regulation — Regulation (EU) 2019/1020, Article 4: Have a responsible person in the union who can show the documentation to a supervising body.
The rows behind the answer
European Union
- Market Surveillance Regulation — Regulation (EU) 2019/1020: Goods entering the Union market need a reachable responsible person and documentation on request.
United States
No US row in our register for this topic. That is a gap in the register, not a statement that no rule exists.
China
- Export Control Law of the People's Republic of China: Control lists, licensing and end user duties for controlled items leaving China.
- Regulations on Export Control of Dual-Use Items: Licensing procedure and control list handling for dual use items.
Where companies usually start
- Check the item against the control list before quoting a delivery date.
- Record the end use statement with the order, not in a mailbox.
- Name the EU responsible person for the same goods in the same file.
This page reads published registers and describes common practice. It is not legal advice and it is not a compliance verdict.
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Machine-readable summaries for AI agents: /llms.txt and /llms-full.txt.
