China to control exports of tunnel boring machines and drone parts from November 18

China’s Ministry of Commerce (MOFCOM) published four dual-use export control notices on October 19. No. 49 adjusts drone rules, No. 50 adds tunnel boring machines and other engineering machinery, No. 51 widens controls on dredgers and No. 52 details the customs query procedure. The first three take effect on November 18, 2026; the last is already in force.

For drones, Notice 49 raises one controlled category’s endurance threshold from 1 hour to 3 hours, which, according to a legal analysis published by CTILS, may free some models. At the same time, separately sold components become controlled: propeller brushless motors rated at 48 V or more, 3 kW or more, 3 kW/kg or more and up to 3,000 rpm, plus matching electronic speed controllers, carbon-fibre propellers (new item 9A901), plus related software and technology.

Notice 50 covers full-face tunnel boring machines, walking excavators and high-altitude wet shotcrete machines, with parts and technology. Exports to “sensitive countries and regions in dispute with China” need a licence; for others, exporters obtain the document by registering information, subject to end-use and re-transfer limits, CTILS says. Notice 51 adds dredge pumps, casings, impellers, drag heads and cutters.

Exporters must state on the customs declaration whether an item is controlled and, when parameters are close to the threshold, declare that it is not. If in doubt, customs opens a query and the goods are not released; Notice 52 sets 15 working days for customs and 15 for MOFCOM and allows unrelated goods to be split off.

CSP take: since Brazil has no dispute with China, shipments here should fall under registration rather than licensing. Even so, registration and technical declaration become a mandatory step for exporting any TBM, dredger or drone part. Ask suppliers for spec sheets against the notice’s parameters and agree in the contract who bears release delays. This reading is ours, not MOFCOM’s.