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China Adds Tunnel Boring Machines, Walking Excavators, and High-Altitude Wet Sprayers to Export Control List: What Foreign Founders Need to Know

China's MOFCOM and GAC Announcement No. 50 of 2026 imposes export controls on tunnel boring machines, walking excavators, and high-altitude wet spraying machines, effective November 18, 2026. Foreign founders operating in China must understand licensing requirements and compliance obligations.

New Export Controls on Construction Equipment

On October 19, 2026, China's Ministry of Commerce (MOFCOM) and General Administration of Customs (GAC) jointly issued Announcement No. 50 of 2026, introducing export controls on specific types of construction machinery. The measure, approved by the State Council and grounded in the Export Control Law, Foreign Trade Law, Customs Law, and Regulations on Export Control of Dual-Use Items, takes effect on November 18, 2026. For foreign founders whose China-based companies manufacture, trade, or export such equipment, this development brings new compliance obligations.

The announcement targets three categories: tunnel boring machines and related parts and technology, walking excavators and related technology, and high-altitude wet spraying machines and related parts and technology. The controls are implemented through the dual-use item export control regime, meaning that exports of listed items require prior authorization from Chinese authorities.

Items Subject to Export Controls

Tunnel Boring Machines (2B906, 2A906, 2E906)

The controls cover full-face tunnel boring machines, including earth pressure balance shields, slurry shields, and other shield types, as well as open-type, single-shield, and double-shield rock tunnel boring machines and other rock TBMs. The referenced customs commodity code is 8430313010. Additionally, parts specially designed for these machines are controlled: cutter heads (code 8431499910), screw conveyors (code 8428310010), segment erectors (code 8479899959), and main drive systems and other key units (code 8431499910). Remanufacturing technology specially designed for controlled TBMs or their parts is also listed under 2E906.

Walking Excavators (2B904, 2E904)

Walking excavators are controlled if they meet any one of four thresholds: vertical obstacle crossing height exceeding 1.2 meters; wading depth exceeding 1.5 meters; trench crossing width exceeding 3 meters; or walking gradeability exceeding 40 degrees. The customs commodity code is 8429521920. A technical note defines walking excavators as mechanical equipment that uses combined actions of working devices, legs, or wheels to achieve self-propulsion, enabling multifunctional excavation across all terrains. Hydraulic system electro-hydraulic proportional control technology specially designed for these excavators is also controlled under 2E904.

High-Altitude Wet Spraying Machines (2B903, 2A903, 2E903)

Wet spraying machines for use above 3,000 meters altitude are controlled if they meet all five criteria: 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 for the hydraulic system. The customs commodity code is 8479109010. A technical note explains that high-altitude wet spraying machines transport mixed materials (such as concrete) to a nozzle and spray them onto the work surface by adding air and accelerator. Parts specially designed for these machines are also controlled under 2A903, including high-altitude engines (codes 8408909240, 8408909330), engine auxiliary oxygen supply devices (code 8421399030), high-altitude motors (codes 8501520020, 8501530020), two-stage air compressors (code 8414804110), high-altitude chassis (code 8479909030), and folding arms (code 8479909030). Hydraulic and pumping technology specially designed for these machines is controlled under 2E903.

Licensing and Compliance Requirements

Exporters intending to ship any of 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 under the Export Control Law and the Dual-Use Items Regulations. Without a license, such exports are prohibited. For exports to other countries and regions worldwide, exporters must obtain an export certificate through a registration and information filing process. Both the exporter and the end user must commit that, without authorization, they will not transfer or provide the China-origin items to countries or regions that have 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.

Exporters are responsible for the authenticity of customs declarations. They must strengthen the identification of export items. If an item is controlled, the remark column of the customs declaration must state "belongs to dual-use items" and list the dual-use item export control code. If an item is not controlled but its parameters, indicators, or performance are close to the controlled thresholds, the remark must state "does not belong to dual-use items" and provide specific parameters and indicators. Customs will question declarations that are complete, accurate, or authentic but suspicious; during the questioning period, the goods will not be released.

The announcement takes effect on November 18, 2026, and the Dual-Use Items Export Control List is updated accordingly.

Practical Implications for Foreign Founders

If your China-based company manufactures, trades, or exports construction equipment, you should immediately review your product portfolio against the controlled items and technical thresholds. Export compliance procedures must be integrated into your sales and shipping workflows. For exports to sensitive destinations, license applications may be required. For other destinations, a registration-based export certificate is necessary, along with end-user commitments. Accurate customs declarations are critical to avoid delays or penalties.

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.