*The export license for dual-use items of artificial graphite is a type of license required for exporting graphite electrodes and other items overseas.

【Dual-Use Items】FAQ Series (Graphite-Related)

1. How can exporters determine whether the graphite items they intend to export are classified as controlled dual-use items?
Exporters should refer to the Announcement No. 39 of 2023 by the Ministry of Commerce and the General Administration of Customs regarding the optimization and adjustment of temporary export control measures for graphite items. If they are unable to make a determination, they may apply for an export consultation through the unified platform of the business system (https://ecomp.mofcom.gov.cn/loginCorp.html),  stating the technical specifications, main applications, and reasons for the inability to determine the classification. The Ministry of Commerce will organize an assessment and respond in a timely manner.

2. How should the descriptions of high purity, high strength, and high density graphite in Announcement No. 39 of 2023 be interpreted?
Graphite materials and products that simultaneously meet all three of the following criteria are subject to dual-use item controls:
① High purity (purity > 99.9%),
② High strength (flexural strength > 30 MPa),
③ High density (density > 1.73 g/cm³).
When applying for the relevant export license, exporters should include the actual values for purity, flexural strength, and density in the technical documentation or test reports of the graphite materials and products.

3. Are synthetic graphite powders subject to dual-use item controls?
Synthetic graphite powders do not possess the technical indicator of flexural strength and therefore cannot simultaneously meet the requirements of high purity (>99.9%), high strength (>30 MPa), and high density (>1.73 g/cm³). Thus, they are not currently within the scope of dual-use item controls.

4. Are graphite products reinforced with metals or fibers subject to dual-use item controls?
Graphite packing rings, gaskets, composite sheets, wires, and rings reinforced with materials such as cotton fiber, glass fiber, asbestos, aramid PTFE, or polytetrafluoroethylene are not currently within the scope of dual-use item controls.

5. If the quantity on the application form is in kilograms, but the contract uses other units, how should it be handled?
Some export contracts for graphite items may use pounds, pieces, or other units. When filling out the export license application form, enterprises must convert the unit into kilograms and provide a description of the conversion calculation.

6. Is the original copy of the "End-User and End-Use Certificate" required?
Yes, the original is required and must be personally signed and stamped by the person in charge of the end-user.

7. How should the end use of the export item be described?
Exporters must thoroughly understand and verify the final use of the export item. In the application materials, the end use should be described specifically and accurately, e.g., for the production of engine gaskets, refractory bricks, or flame retardants, rather than general descriptions of use sectors.

8. Can the end-use descriptions on the application form and in other related materials differ?
No, the end-use descriptions in both Chinese and English must be completely consistent across the application form and all related materials.

9. Can the consignee on the application form be an intermediary?
If there is an intermediary between the importer and the end-user, the consignee can be the intermediary. However, additional explanation is required, or relevant documents such as contracts or agreements between the intermediary and the importer/end-user must be provided.

10. Can the legal representative's signature on the application form be replaced with a name stamp?
No, the legal representative must personally sign the application form. A name stamp is not acceptable. If another person signs on behalf of the legal representative, an official power of attorney signed by the legal representative must be submitted.

11. What are the requirements for the supplementary explanation of the rationality of the export quantity?
Exporters may explain the reasonableness of the export quantity based on the end-user's history of imports, production scale, and import needs.

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