On July 31, 2024, the Ministry of Commerce, jointly with the General Administration of Customs and the Equipment Development Department of the Central Military Commission, issued Announcement No. 31 of 2024, Announcement on Optimizing and Adjusting the Export Control Measures for Unmanned Aerial Vehicles, which will come into effect on September 1, 2024. At the same time, Announcement No. 27 and No. 28 of 2023 are repealed. The following is a detailed analysis of the terms and rules of this announcement.

I. Repeal of Temporary Control, Benefiting the Export of Consumer - grade Unmanned Aerial Vehicles

The announcement repeals Announcement No. 28 of 2023, which means that as of September 1, 2024, the temporary - controlled products in Announcement No. 28 of 2023 are allowed to be exported, which is very beneficial to the export of consumer - grade unmanned aerial vehicle products. However, the new announcement still clearly stipulates that if an export operator knows or should know that the export will be used for the proliferation of weapons of mass destruction, terrorist activities, or military purposes, it shall not export.

To facilitate customs document review, when enterprises export relevant products originally under temporary control, it is recommended to provide a stamped statement of purpose and upload it to the attached documents. The following are the HS codes of the products allowed to be exported:

• 8806100010
• 8806221011
• 8806229010
• 8806231011
• 8806239010
• 8806241011
• 8806249010
• 8806291011
• 8806299010
• 8806921011
• 8806929010
• 8806931011
• 8806939010
• 8806941011
• 8806949010
• 8806990010

II. Relaxation of the Product Control Scope

Infrared imaging equipment

• Announcement No. 31, 2024: Export control is required only when all of the following characteristics are met (Refer to Customs commodity codes: 8525891110, 8525892110, 8525893110).
  • The wavelength range is between 780 nanometers (nm) and 30000 nanometers (nm);
  • The Instantaneous Field of View (IFOV) is less than 2.5 milliradians (mrad).
• Announcement No. 27, 2023: Export control is required if any of the above characteristics is present.

Lasers for target indication

• Announcement No. 31, 2024: Export control is required only when all of the following characteristics are met (Refer to Customs commodity code: 9013200093).
  • It can operate stably in an environment above 55 degrees Celsius (℃);
  • It is temperature - control - free type;
  • The energy is greater than 80 millijoules (mJ);
  • The stability is better than 15%;
  • The beam divergence angle is less than 0.3 milliradians (mrad).
• Announcement No. 27, 2023: Export control is required if any of the above characteristics is present.

III. Newly Added Export - controlled Products

Announcement No. 31, 2024 has added export control on the following inertial measurement equipment (Refer to Customs commodity code: 9014209014. Currently, this Customs commodity code is not available in the single - window system, and the HS will be added in due course):

• The heading accuracy is less than 2 degrees (°);
• The attitude accuracy is less than 0.5 degrees (°);
• The resolution is less than 0.1 degrees (°).

IV. Changes in the Joint Issuing Units

Compared with Announcements No. 27 and No. 28 of 2023, the jointly issued Announcement No. 31 of 2024 has one less participating unit, namely the "State Administration of Science, Technology and Industry for National Defense."

Analysis and Interpretation of the Announcement

This announcement has optimized and adjusted the export control measures for unmanned aerial vehicles, mainly reflecting the following changes and significance:

1. Abolition of temporary control: It is extremely beneficial to the export of consumer - grade unmanned aerial vehicles. The restrictions on low - risk products have been lifted, which helps to expand the market share.
2. Relaxation of control scope: The control conditions for infrared imaging equipment and lasers for target indication are more stringent. They will be controlled only when multiple conditions are met simultaneously, reducing the compliance burden on enterprises.
3. Addition of controlled products: The control of high - precision inertial measurement equipment has been clarified to ensure that sensitive technologies are not misused.
4. Change in issuing units: The number of co - issuing units has been reduced, simplifying the management process, which may reflect the optimization of control measures and the adjustment of division of responsibilities.

Overall, while relaxing and optimizing the control measures, this announcement still maintains strict supervision over high - risk products, balancing the needs of trade facilitation and national security. When exporting unmanned aerial vehicles, enterprises should carefully read and comply with the provisions of the new announcement to ensure compliant operation.