Home/Trade Route/HS 6202

Cross-Border Trade Guide

🇺🇸 United States 🇨🇳 China

HS 6202 · WOMEN'S OR GIRLS' OVERCOATS ETC, EXCEPT HEAD 6203Annual bilateral volume: $614M

Estimated Duties

14-20%

MFN 14-20% + 13% import VAT

Transit Time

15-35 days

End to end

Compliance

GB 18401

Textile national safety standard

Export Rebate

N/A

No export VAT (none applies)

Key Rules

United States 🇺🇸 China 🇨🇳

US Export Certifications
Commercial Invoice [USX]
Shipper's Letter of Instruction (SLI) [USX]
Bill of Lading (B/L) or Air Waybill (AWB) [USX]
Electronic Export Information (EEI) / AES Filing [USX]
Certificate of Origin [USX]
Packing List [USX]
Destination Control Statement (DCS) [USX]
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Estimated Cost Breakdown

per $100K shipment · United StatesChina

DUTY CALCULATION — CHINA

Base Duty

0%

MFN (ITA): Free

VAT 13%

13%

on (CIF + duty)

Effective Total

~0%

duty only

Product cost (FOB)$100,000
Ocean freight (est.)$3,500
Marine insurance (0.4%)$400
VAT 13% on $103,900$13,507
Customs broker~$75
Estimated total landed cost~$117,482

* Estimates based on $100K FOB shipment of electronics (HS 85). Actual costs vary by exact HS code, weight/volume, and current rates.

CERTIFICATIONS
US Export Certifications
No general export certification required. However: EAR-controlled items: export license from BIS (Bureau of Industry and Security). ITAR-controlled defense articles: license from DDTC (Directorate of Defense Trade Controls). Nuclear materials: license from NRC. For most commercial goods (electronics, machinery): NO certification needed, only proper ECCN classification.
§REQUIRED DOCUMENTS
Commercial Invoice [USX]
Required for all exports. Must include: exporter and consignee details, description of goods, quantity, unit value, total value (in USD), country of origin, Incoterms, ECCN or EAR99 designation, Schedule B number. No prescribed format but must be complete and accurate.
Shipper's Letter of Instruction (SLI) [USX]
Authorizes the freight forwarder to act on behalf of the exporter for EEI filing and export processing. Contains: exporter info, consignee, intermediate consignee, forwarding agent, transport details, ECCN, Schedule B number, value, license information. Not a government form but industry standard. Essential when using a freight forwarder.
Bill of Lading (B/L) or Air Waybill (AWB) [USX]
Transport document issued by carrier. Ocean: Bill of Lading (negotiable or non-negotiable). Air: Air Waybill (always non-negotiable). Must include ITN from AES filing. Serves as receipt of goods, contract of carriage, and (for negotiable B/L) document of title.
Electronic Export Information (EEI) / AES Filing [USX]
The electronic declaration filed via AESDirect or AES-compatible software. Contains: USPPI (exporter) info, ultimate consignee, intermediate consignee, Schedule B number, ECCN, quantity, value, export carrier, port of export, country of destination, license information. Results in ITN that must accompany shipment.
Certificate of Origin [USX]
Required by many destination countries to verify goods are of US origin. For preferential trade agreements (USMCA, KORUS FTA, etc.): specific certificate format required. General certificates: issued by local Chamber of Commerce. Some countries require consular legalization (additional step).
Packing List [USX]
Detailed list of goods in each package/container. Includes: description, quantity, weight, dimensions, marks and numbers. Used by customs at destination, carrier, and insurance company.
Destination Control Statement (DCS) [USX]
Required on commercial invoice and B/L for items controlled under EAR or ITAR. Standard text: 'These commodities, technology, or software were exported from the United States in accordance with the Export Administration Regulations. Diversion contrary to U.S. law is prohibited.' Required per 15 CFR 758.6.
Export License (if applicable) [USX]
Physical or electronic license from BIS (EAR items) or DDTC (ITAR items). Must be referenced on EEI filing. License number must appear on commercial invoice. BIS licenses: typically valid for 4 years. DDTC licenses: typically valid for 4 years. Some transactions qualify for License Exceptions (no individual license but conditions apply).
PROCESS STEPS
Register in ACE/AES System [USX]
US exporters must register with the Automated Commercial Environment (ACE) system to file Electronic Export Information (EEI). ACE is CBP's primary system; AES (Automated Export System) is the export component within ACE. Register via ACE portal or through a licensed customs broker/freight forwarder. No registration fee. Requires EIN (Employer Identification Number) or SSN for sole proprietors.
Classify Your Product (ECCN / Schedule B) [USX]
Before exporting, determine if your product is controlled. Two classification systems: (1) ECCN (Export Control Classification Number) — determines if an export license is needed under EAR. Check the Commerce Control List (CCL). Most commercial goods are 'EAR99' (no license needed for most destinations). (2) Schedule B Number — the 10-digit statistical classification used for EEI filing. BIS provides a free ECCN classification request service (commodity classification request, SNAP-R). Self-classification is allowed and most common.
Screen Parties and Check Restrictions [USX]
Before any export, screen all transaction parties against the Consolidated Screening List (CSL): Entity List (BIS), Denied Persons List (BIS), Unverified List (BIS), SDN List (OFAC/Treasury), Debarred List (DDTC/State). Free screening tool at trade.gov. Also check destination country for embargo/sanctions (OFAC). Failure to screen can result in civil penalties up to $364,992 per violation or criminal penalties up to $1,000,000 and 20 years imprisonment.
Obtain Export License (if required) [USX]
If your ECCN + destination + end-use/user combination requires a license, apply via BIS SNAP-R system. License types: Individual Validated License (IVL), License Exception (e.g., TMP, LVS, TSR, GOV). Processing time: typically 30-60 days. BIS must respond within 90 days by law. Many commercial electronics to allied countries qualify for License Exception (no individual license needed). ITAR items: apply via DDTC DSP-5 form (different system entirely).
File Electronic Export Information (EEI) via AES [USX]
EEI filing is REQUIRED when: (1) value per Schedule B number exceeds $2,500, OR (2) an export license is required regardless of value, OR (3) goods are destined for certain sanctioned countries. File via AESDirect portal (free) or through AES-compatible software. Deadline: non-ITAR items — 2 hours before export; ITAR items — 8 hours before export. Postdeparture filing: pre-approved exporters can file within 5 calendar days after export. EXEMPTION: Shipments to Canada under $2,500 are exempt from EEI filing. Upon filing, receive Internal Transaction Number (ITN) — must be provided to carrier.
Arrange Transport and Provide ITN to Carrier [USX]
After EEI filing, provide the ITN to the carrier (shipping line, airline, freight forwarder). The carrier must include the ITN on the manifest/bill of lading. For ocean freight: goods must be delivered to port for loading. For air freight: delivered to airline cargo facility. Freight forwarder handles physical logistics, carrier booking, and export customs clearance.
Post-Export Record Keeping [USX]
Exporters must retain all export records for 5 years from date of export. Records include: EEI data, commercial invoices, shipping documents, export licenses, correspondence with BIS/DDTC, end-use statements, screening records. BIS and Census Bureau may audit at any time. Penalty for failure to maintain records: up to $12,000 per violation.
PROCESS STEPS
Register in ACE/AES System [USX]
US exporters must register with the Automated Commercial Environment (ACE) system to file Electronic Export Information (EEI). ACE is CBP's primary system; AES (Automated Export System) is the export component within ACE. Register via ACE portal or through a licensed customs broker/freight forwarder. No registration fee. Requires EIN (Employer Identification Number) or SSN for sole proprietors.
Classify Your Product (ECCN / Schedule B) [USX]
Before exporting, determine if your product is controlled. Two classification systems: (1) ECCN (Export Control Classification Number) — determines if an export license is needed under EAR. Check the Commerce Control List (CCL). Most commercial goods are 'EAR99' (no license needed for most destinations). (2) Schedule B Number — the 10-digit statistical classification used for EEI filing. BIS provides a free ECCN classification request service (commodity classification request, SNAP-R). Self-classification is allowed and most common.
Screen Parties and Check Restrictions [USX]
Before any export, screen all transaction parties against the Consolidated Screening List (CSL): Entity List (BIS), Denied Persons List (BIS), Unverified List (BIS), SDN List (OFAC/Treasury), Debarred List (DDTC/State). Free screening tool at trade.gov. Also check destination country for embargo/sanctions (OFAC). Failure to screen can result in civil penalties up to $364,992 per violation or criminal penalties up to $1,000,000 and 20 years imprisonment.
Obtain Export License (if required) [USX]
If your ECCN + destination + end-use/user combination requires a license, apply via BIS SNAP-R system. License types: Individual Validated License (IVL), License Exception (e.g., TMP, LVS, TSR, GOV). Processing time: typically 30-60 days. BIS must respond within 90 days by law. Many commercial electronics to allied countries qualify for License Exception (no individual license needed). ITAR items: apply via DDTC DSP-5 form (different system entirely).
File Electronic Export Information (EEI) via AES [USX]
EEI filing is REQUIRED when: (1) value per Schedule B number exceeds $2,500, OR (2) an export license is required regardless of value, OR (3) goods are destined for certain sanctioned countries. File via AESDirect portal (free) or through AES-compatible software. Deadline: non-ITAR items — 2 hours before export; ITAR items — 8 hours before export. Postdeparture filing: pre-approved exporters can file within 5 calendar days after export. EXEMPTION: Shipments to Canada under $2,500 are exempt from EEI filing. Upon filing, receive Internal Transaction Number (ITN) — must be provided to carrier.
Arrange Transport and Provide ITN to Carrier [USX]
After EEI filing, provide the ITN to the carrier (shipping line, airline, freight forwarder). The carrier must include the ITN on the manifest/bill of lading. For ocean freight: goods must be delivered to port for loading. For air freight: delivered to airline cargo facility. Freight forwarder handles physical logistics, carrier booking, and export customs clearance.
Post-Export Record Keeping [USX]
Exporters must retain all export records for 5 years from date of export. Records include: EEI data, commercial invoices, shipping documents, export licenses, correspondence with BIS/DDTC, end-use statements, screening records. BIS and Census Bureau may audit at any time. Penalty for failure to maintain records: up to $12,000 per violation.
SHIPPING & TIMELINE
Shipping Timeline from China
China → US (West Coast): Ocean 15-20 days, $2,800-4,200/FEU. Air 3-5 days, $5-8/kg. China → US (East Coast): Ocean 25-35 days, $3,500-5,500/FEU. China → Japan: Ocean 3-7 days, $500-1,200/FEU. Air 1-2 days, $3-6/kg. China → EU (Rotterdam): Ocean 25-35 days via Suez, $2,500-4,500/FEU. China → Korea: Ocean 2-4 days, $300-700/FEU. Export customs clearance: typically 1-2 days after declaration.
China Import Customs Clearance Timeline [CNI]
Average customs clearance time (from declaration to release): Standard goods: 1-3 business days (Single Window has reduced from 16 hours to ~2 hours for green channel). Goods requiring inspection: 3-7 business days. First-time imports with lab testing: 15-20 business days. Major port processing times (2026): Shanghai (洋山/外高桥): 1-2 days average. Shenzhen (盐田/蛇口): 1-2 days. Guangzhou (南沙): 1-2 days. Qingdao (青岛): 2-3 days. Tianjin (天津): 2-3 days. AEO-certified enterprises: typically same-day or next-day clearance.
Shipping Timeline: US to China [CNI]
Ocean freight: US west coast (LA/Long Beach) → Shanghai/Shenzhen: 15-20 days. US east coast (NY/Savannah) → Shanghai: 25-35 days. Transit via Pacific: most common route for US-China trade. Air freight: 2-4 days (major airports: LAX→PVG, JFK→PEK, ORD→CAN). Ocean container cost (2026): $1,500-3,500/FEU (US→China direction typically cheaper than China→US). Air freight cost: $4-8/kg. Add 1-3 days for China customs clearance (standard goods).
Shipping Timeline from US
US → China: Ocean (LA→Shanghai) 15-20 days, $2,500-4,000/FEU. Air 3-5 days, $5-8/kg. US → Japan: Ocean (LA→Tokyo) 10-14 days, $2,000-4,000/FEU. Air 2-3 days, $5-8/kg. US → EU: Ocean (NY→Rotterdam) 10-14 days, $2,000-3,500/FEU. Air 1-2 days, $4-7/kg. US → Korea: Ocean 12-16 days, $2,000-3,500/FEU. EEI filing: must be done before export. AES processing: near-instant.
Typical Shipping Timeline: China to US
Ocean freight (China east coast to US west coast): 15-20 days. Ocean freight (to US east coast): 25-35 days. Air freight: 3-5 days. Rail (via Canada): 20-25 days. Add 3-7 days for US customs clearance.
§REQUIRED DOCUMENTS
Import Customs Declaration Form (进口报关单) [CNI]
Primary customs document filed electronically via Single Window. Contains 50+ data fields including: consignee code, HS code, quantity, value, trade terms, transport mode, country of origin. One declaration per B/L (or consolidated for multiple B/Ls from same consignment).
Commercial Invoice (商业发票) [CNI]
Must include: seller, buyer, contract number, description, quantity, unit price, total amount, trade terms (Incoterms), payment terms. Used for customs valuation. Chinese customs may challenge declared value if significantly below reference prices.
Packing List (装箱单) [CNI]
Detailed contents of each container/package: item description, quantity per package, gross weight, net weight, dimensions, marks and numbers. Must match commercial invoice.
Bill of Lading / Air Waybill (提单/空运单) [CNI]
Ocean: Original Bill of Lading (usually 3 originals). Air: Air Waybill. B/L number is linked to customs declaration. Required for cargo release from port terminal.
Trade Contract (贸易合同) [CNI]
Import contract between buyer and seller. Must be presented to customs if requested. Key elements: parties, product description, quantity, price, payment terms, trade terms, delivery schedule. Customs may request to verify value declarations.
Insurance Policy/Certificate (保险单) [CNI]
Required if goods are insured (standard for CIF terms). Insurance certificate or policy showing coverage amount and risks covered. Used in customs valuation for CIF-based assessment.
Certificate of Origin (原产地证书) [CNI]
Required for claiming preferential tariff rates under FTAs/RCEP. For RCEP: issued by authorized body (e.g., CCPIT for Chinese exports) or approved exporter self-declaration. For MFN rates: not strictly required but customs may request. For non-preferential purposes: proves origin for trade statistics and potential retaliatory tariff application.
Inspection/Quarantine Certificate (检验检疫证书) [CNI]
Required for goods in the Statutory Inspection Catalog. Includes: health certificate (food/animal products), phytosanitary certificate (plants), quality inspection certificate, safety certificate. Must be obtained from exporting country's competent authority before shipping.
Import License (进口许可证) — If Required [CNI]
Required for goods in the Import License Management Catalogue (2026 version: MOFCOM/GACC Announcement 2025 No.88). Covers: certain machinery, electronics requiring approval, ozone-depleting substances, controlled chemicals, endangered species products. Automatic import license (自动进口许可证) for monitored goods: issued within 3 working days.
PROCESS STEPS
Importer Registration and Qualification [CNI]
Foreign trade operators must register with MOFCOM (商务部) for import/export rights (对外贸易经营者备案). Then register with local Customs (海关注册登记). Both done via China International Trade Single Window (国际贸易单一窗口, singlewindow.cn). Registration is free and takes 1-3 business days. Foreign companies must import through a registered Chinese entity (subsidiary, agent, or consignee). Customs registration number (海关注册编码, 10 digits) is required for all declarations.
Pre-Arrival Preparation and Inspection Application [CNI]
For goods in the Statutory Inspection Catalog (法定检验目录), apply for CIQ inspection BEFORE arrival. Submit to local China Customs (previously separate CIQ bureau, merged into Customs in 2018). Food, cosmetics, medical devices require pre-registration of overseas manufacturers with GACC. Pre-arrival customs declaration allowed (提前申报) — can file up to 24 hours before vessel arrival.
Submit Import Customs Declaration (进口报关) [CNI]
File electronically via China International Trade Single Window or China E-Port (中国电子口岸). Declaration form (报关单) includes: consignee, HS code (8 or 10 digits), quantity, value, trade terms (Incoterms), transport mode, country of origin, destination port. Customs broker (报关行) typically handles declaration. Must be filed within 14 days of vessel arrival (penalty for late filing: 0.05% of duty per day, max 30%).
Customs Review and Inspection (审单/查验) [CNI]
Customs applies risk-based review: (1) Green channel — auto-release (majority of shipments). (2) Yellow channel — document review. (3) Red channel — physical inspection. Inspection rate varies: ~5% for general goods, higher for first-time importers and high-risk products. AEO-certified enterprises (高级认证企业) get significantly lower inspection rates (~0.5%). If inspection required: goods presented at customs supervision area, typically takes 1-2 days.
Pay Duties, VAT, and Consumption Tax (税费缴纳) [CNI]
After customs release, importer receives tax payment notice (税款缴款书). Must pay within 15 days of receipt. Components: (1) Import duty (关税) — based on HS code rate x customs value (CIF). (2) Import VAT (进口增值税) — 13% standard, calculated on (CIF + duty + consumption tax). (3) Consumption tax (消费税) — only on specific luxury/resource goods. Payment via bank transfer, electronic payment, or customs guarantee. Late payment: 0.05% per day (滞纳金).
Goods Release and Post-Clearance Audit (放行/后续监管) [CNI]
After duties paid and inspection passed, customs issues release notice (放行通知). Goods can be picked up from port/warehouse. Post-clearance audit (海关稽查): Customs can audit import records for up to 3 years after import. 5 years for goods subject to duty reduction/exemption or bonded treatment.
¤TARIFF & DUTIES
China MFN Tariff on Japanese Goods — Electronics
Most electronics from Japan are Free (0%) under ITA, same as other WTO members. RCEP provides preferential rates on non-ITA products. China's standard VAT on imports: 13%. No special tariffs on Japanese goods (unlike US 301). Note: China banned Japanese seafood imports since August 2023 (Fukushima water release). Status as of 2026: seafood ban partially eased under diplomatic negotiations.
China Import Tariff Structure — Overview [CNI]
China's import tariff has multiple layers applied in order of priority: (1) Provisional rates (暂定税率): lowest, applied to 935 items in 2026 to encourage imports of strategic goods. (2) MFN rates (最惠国税率): apply to WTO member goods, default for most trading partners. (3) FTA/RCEP conventional rates (协定税率): preferential rates under 24 FTAs with 34 partners. (4) General rates (普通税率): highest, apply to non-WTO/non-FTA countries (rare in practice). Priority: Provisional > FTA/RCEP > MFN > General. Electronics (HS 85) MFN rates: mostly 0% under WTO ITA (Information Technology Agreement). China joined ITA in 2003; covers most HS 8471, 8517, 8518, 8528 sub-headings.
China Import Tariff — Electronics Rates (HS 85) [CNI]
Under the ITA, most electronics have 0% MFN tariff. Key HS codes: 8471 (computers): 0%. 8517 (telecom equipment including smartphones): 0%. 8518 (speakers, headphones): 0%. 8528 (monitors, projectors): 0%. 8541/8542 (semiconductors, ICs): 0%. NON-ITA electronics with tariffs: 8509 (household appliances): 7-10%. 8516 (electric heaters, hair dryers): 7-10%. 8508 (vacuum cleaners): 10%. 2026 provisional rates: further reduced for specific components (e.g., CNC parts, certain sensors).
China Import Tariff — RCEP Preferential Rates [CNI]
RCEP entered into force for China on January 1, 2022. Partners: Japan, Korea, Australia, NZ, ASEAN. China eliminates tariffs on ~91% of tariff lines over 10-20 years. For electronics (already 0% under ITA): RCEP provides no additional tariff benefit. Key benefits of RCEP for China imports: chemicals, machinery parts, auto parts, processed foods, textiles. Requires RCEP Certificate of Origin; regional cumulation rules allow content from all 15 RCEP members. Japan is the most significant new partner — first-ever tariff arrangement between China and Japan.
China Import Tariff — Retaliatory Tariffs on US Goods (2026 Status) [CNI]
China imposed retaliatory tariffs on US goods starting 2018, escalated through 2025. Under the Busan Agreement (Oct 30, 2025): China SUSPENDED all retaliatory tariffs imposed since March 2025. Pre-Busan retaliatory tariffs (2018-2019 rounds) remain: 5-25% on ~$110B of US goods. Key affected US exports: soybeans (25%), automobiles (25%), LNG (25%), aircraft (10%), certain electronics components (10-25%). Note: These are ON TOP of MFN rates and apply specifically to US-origin goods.
CERTIFICATIONS
CCC Certification (3C认证) for Imports [CNI]
China Compulsory Certification is mandatory for ALL products sold in China (domestic or imported). 17 major categories, ~123 product types. Electronics covered: household appliances, IT equipment, audio/video equipment, lighting, telecom terminals. Process: (1) Apply to CNCA-designated certification body (e.g., CQC). (2) Submit samples for testing at designated lab. (3) Factory inspection (for foreign manufacturers). (4) Receive CCC certificate. Timeline: 2-4 months. Cost: $5,000-$15,000. Products WITHOUT CCC cannot clear customs for domestic sale. Exemptions: goods for personal use, exhibition only, processing trade for re-export.
SRRC Radio Approval (型号核准) for Imports [CNI]
Mandatory for ALL radio-transmitting devices sold/used in China. Covers: Wi-Fi, Bluetooth, cellular, NFC, RFID, GPS, any RF-emitting equipment. Issued by MIIT (工信部). Testing at MIIT-authorized labs (e.g., CTTL, SRMC). Must be obtained BEFORE CCC application (SRRC is a prerequisite for CCC on wireless products). Timeline: 4-8 weeks. Cost: $2,000-$5,000 per model.
CIQ Statutory Inspection (法定检验) for Imports [CNI]
Goods in the Statutory Inspection Catalog (法检目录) must undergo CIQ inspection before domestic sale. Inspection covers: safety, quality, hygiene, environmental protection, fraud prevention. Categories: food, animal/plant products, cosmetics, machinery, electronics (selected), chemicals, textiles. Process: (1) Apply for inspection at port of entry customs. (2) Sampling and testing. (3) Receive CIQ inspection certificate (入境货物检验检疫证明). Timeline: 1-5 business days for standard goods; 15-20 days for first-time imports requiring lab testing. Without CIQ certificate, goods cannot be sold or used domestically.
NMPA Registration for Medical Devices and Drugs [CNI]
National Medical Products Administration (NMPA, formerly CFDA) registration required for: ALL imported medical devices (Class I, II, III) and pharmaceutical drugs. Class I: filing (备案) with local NMPA, simplest. Class II: registration with provincial NMPA. Class III: registration with national NMPA — most stringent, requires clinical trials in China. Drugs: import license from NMPA required. Clinical trials in Chinese population often required. Timeline: Class II — 6-12 months. Class III — 1-3 years. Drugs — 2-5 years. Not applicable to standard electronics (HS 85) unless classified as medical devices.
China RoHS (电器电子产品有害物质限制使用管理办法) [CNI]
China RoHS II (effective January 1, 2019): restricts 6 hazardous substances in EEE products: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE. Two stages: (1) ALL EEE products must provide SJ/T 11364 disclosure label showing hazardous substance content. (2) Products in the 'Conformity Assessment Catalog' must undergo mandatory testing and certification — currently covers 12 product categories (TVs, monitors, printers, etc.). Different from EU RoHS: China RoHS uses a disclosure + catalog approach, not a blanket ban. Non-compliance: product may be barred from sale or import.
NAL (Network Access License) for Telecom Equipment [CNI]
Telecom terminal equipment connected to public telecom networks requires NAL (网络接入许可, 进网许可). Issued by MIIT. Covers: smartphones, routers, switches, modems, base stations. Requires: SRRC radio approval + NAL testing at MIIT labs. Timeline: 2-3 months. Cost: $3,000-$8,000. Required in addition to CCC for telecom products.

Export-Side Restrictions

Controls imposed by United States

EAR Export Controls — Commerce Control List (CCL) [USX]
The Export Administration Regulations (EAR) govern export of commercial and dual-use items. The CCL has 10 categories: 0-Nuclear, 1-Materials, 2-Materials Processing, 3-Electronics, 4-Computers, 5-Telecom/InfoSec, 6-Sensors/Lasers, 7-Navigation, 8-Marine, 9-Aerospace. Each category has 5 product groups: A-Equipment, B-Test/Production, C-Materials, D-Software, E-Technology. Items NOT on CCL are designated EAR99 — generally exportable without license to most destinations. License requirements determined by ECCN + destination country + end-use + end-user. Country Chart (Supplement No. 1 to Part 738) maps ECCNs to country-specific requirements.
EAR — ECCN Classification and De Minimis Rules [USX]
ECCN is a 5-character code (e.g., 3A001 = certain ICs, 5A002 = encryption equipment). Self-classification is permitted; exporters can also request BIS classification (CCATS, free, 30-day response). DE MINIMIS RULE for re-exports: Foreign-made items incorporating US-origin controlled content are subject to EAR if US content exceeds 25% of total value (10% for embargoed destinations like Cuba, Iran, North Korea, Syria). This triggers license requirements for re-exports. FOREIGN DIRECT PRODUCT RULE (FDPR): Extended in 2022 to cover items produced using US technology/software for Entity List parties — applies globally, affects non-US semiconductor fabs.
EAR — Entity List Restrictions (April 2026) [USX]
The Entity List (Supplement No. 4 to Part 744) includes ~3,163 entities as of late 2025. Majority are Chinese entities in telecom, AI, biotech, quantum, and semiconductors. Export/re-export/transfer to listed entities requires BIS license with presumption of denial for most. Notable Chinese entities: Huawei, SMIC, YMTC, Sophgo, numerous AI/chip companies. BIS '50% Ownership Rule' (Oct 2025): extends restrictions to entities 50%+ owned by listed parties. Affiliates Rule: suspended for 1 year (Nov 2025) under Busan Agreement, reimposed Nov 10, 2026.
ITAR — International Traffic in Arms Regulations [USX]
ITAR regulates defense articles, defense services, and related technical data on the US Munitions List (USML). Administered by DDTC (Directorate of Defense Trade Controls) under State Department. USML has 21 categories (I-Firearms, II-Guns, III-Ammunition, IV-Launch vehicles, V-Explosives, etc.). KEY DISTINCTION: ITAR covers items 'specifically designed or modified' for military use. Commercial electronics are generally NOT ITAR-controlled unless specifically designed for defense. A commercial power supply is EAR99; a power supply 'specifically designed' for a fighter jet is ITAR. ITAR items require State Department license (DSP-5) for ANY export, regardless of destination. Penalties: civil up to $1,213,423/violation; criminal up to $1,000,000 and 20 years.
US Export to China — Semiconductor/AI Chip Controls (April 2026) [USX]
Advanced computing chip exports to China are heavily restricted under EAR. TIMELINE: Oct 2022 — initial controls on advanced chips and semiconductor equipment. Oct 2023 — expanded to close loopholes, tightened thresholds. Dec 2024 — new controls on HBM, advanced equipment, and 140+ new Entity List additions. Jan 2026 — license review policy revised: chips below 21,000 TPP and 6,500 GB/s DRAM bandwidth (roughly H200/MI325X class) evaluated case-by-case instead of presumption of denial. Chips above these thresholds: still presumption of denial. All advanced semiconductor manufacturing equipment: license required, presumption of denial. 16 new entities added to Entity List in Jan 2026 (including Sophgo). 25% tariff on covered AI chips NOT destined for US supply chain (Jan 2026 proclamation).
US Export to China — Technology Transfer Controls [USX]
Beyond physical goods, the US controls 'deemed exports' — release of controlled technology/source code to foreign nationals in the US is treated as an export to their home country. For Chinese nationals working at US companies: access to ECCN-controlled technology may require a deemed export license from BIS. This applies to Categories 3-5 especially (electronics, computers, telecom). Cloud computing: BIS 'IaaS Rule' (Jan 2024+) requires cloud providers to implement KYC for foreign users training large AI models. Expanded in 2025 to cover more compute thresholds. Technical data shared with Chinese subsidiaries/partners also requires EAR compliance review.
US Export to China — Broad EAR Restrictions Summary [USX]
China (including Hong Kong and Macau for many purposes) faces the most comprehensive US export restrictions: (1) Entity List: ~2,000+ Chinese entities. (2) Military End-User (MEU) List: license required for items in Supplement 2 to Part 744. (3) Advanced computing: TPP/bandwidth thresholds. (4) Semiconductor equipment: all advanced tools. (5) Quantum computing: all exports controlled. (6) Supercomputer technology. (7) Certain biotech equipment. (8) Surveillance technology (limited). However: most standard commercial electronics (consumer smartphones, laptops, basic networking) are EAR99 and can be exported to China without a license, as long as no listed entity/end-use is involved.
US Export to Japan — Minimal Restrictions [USX]
Japan is a close US ally and member of all major multilateral export control regimes (Wassenaar Arrangement, MTCR, Australia Group, NSG). Japan is in Country Group A:1 (most favorable treatment under EAR). RESULT: Most items on the CCL can be exported to Japan under License Exceptions, particularly STA (Strategic Trade Authorization) which covers the vast majority of controlled items. EAR99 items: no restrictions. Most ECCN items: License Exception available. Still requires screening against Consolidated Screening List (rare for Japanese entities). EEI filing still required for shipments over $2,500. Japan's own export controls on semiconductors (2023+) align with US controls on China, making Japan a trusted partner in the US export control ecosystem.
US Export to Korea — Minimal Restrictions [KRE]
Korea is a close US ally and member of all 4 multilateral export control regimes. Korea is in US Country Group A:1 (most favorable treatment under EAR). Most items on the CCL can be exported to Korea under License Exceptions, particularly STA (Strategic Trade Authorization). EAR99 items: no restrictions. Still requires Consolidated Screening List check (rare for Korean entities). US-Korea Strategic Trade and Investment Deal (Nov 2025) further strengthens alliance and includes semiconductor supply chain cooperation commitments.

Recent Advisories

Product recalls in the destination market

2026-04-09BISSELL Recalls Over One Million Steam Shot OmniReach Steam Cleaners Due to Risk of Serious Burn Hazard from Attachments
2026-04-09Easymake Adult Portable Bed Rails Recalled Due to Risk of Serious Injury or Death from Entrapment and Asphyxiation; Violates Mandatory Standard for Adult Portable Bed Rails; Imported by ZFZG-US
2026-04-09Halloween Pumpkin Carving Kits Recalled Due to Risk of Serious Injury or Death from Battery Ingestion; Violates Mandatory Standard for Consumer Products with Button Cell Batteries; Sold on Amazon by Besslly Store
2026-04-09LED Lights Recalled Due to Risk of Serious Injury or Death from Battery Ingestion; Violates Mandatory Standard for Consumer Products with Coin Batteries; Sold on Amazon by Happiness Light
2026-04-09Magnetic Drinkware Charms Recalled Due to Risk of Serious Injury or Death from Magnet Ingestion; Violate Mandatory Standard for Magnets; Sold on Amazon by Maitys

Related analysis

Mexico's 1,463-line tariff decree was not industrial policy — it was USTR insurance

December 30 2024: 1,463 Chinese product categories hit with 5-50% duties. The narrative was industrial protection; the mechanics were pre-emptive USTR compliance with IMMEX carve-outs intact.

2026-04-20 · Read →
Disclaimer: Figures are best-effort estimates based on April 2026 public regulations (§122, §232, §301, CBAM, RCEP, etc.). Verify with the relevant customs authority before trade decisions.Report data issue ↗