China's walkie-talkie/radio equipment export: Can I send it without SRRC?
First let’s talk about the conclusion: If ordinary civilian walkie-talkies, Wi-Fi/Bluetooth devices and general short-range remote controls do not meet the technical description of dual-use items, and the uses, users and flows are normal, China’s “dual-use item export license” is usually not required. The absence of SRRC does not mean a ban on export; SRRC targets equipment sold and used in China. However, telemetry or remote control ground equipment, special communications for controlled drones, high-performance cryptography, target detection radars, anti-drone jammers and military communications equipment must be identified first. Those that hit the list can only be exported after obtaining a license from the exporter in mainland China.
As of 2026-08-23: No new announcement on "Comprehensive export ban on ordinary walkie-talkies" has been found
At present, determining whether radio equipment can be exported from China should be based on the unified "Dual-use Items Export Control List", the 2026 Annual License Management Catalog, the "Export Control Law" and the "Dual-use Items Export Control Regulations"; Guo Wu Ban [2025] No. 1 deals with the frequency, installation, model approval and sales use of 150 MHz and 400 MHz walkie-talkies in China.
Article 2 of the official notice is limited to frequency use, installation, development, production, import, sales and maintenance within China; Article 16 only requires walkie-talkies that are "produced or imported for sale and use within my country" to apply for model approval. It cannot be rewritten as "Export prohibited without SRRC".
From that date, applications for approval of new frequencies, stations and models that are inconsistent with the State No. 1 of 2025 will no longer be accepted. This will affect the listing and use in China, but it will not create another export license for walkie-talkies.
The Ministry of Commerce clearly stated that whether a dual-use item is a dual-use item shall be based on the technical description and control code of the list, and is not conditional on whether the HS Code is configured. For example, 5A101 does not list a reference customs commodity number in the 2026 catalog, which does not mean it is not controlled.
Announcement No. 34 of 2026 of the Ministry of Commerce stipulates that exports of drones, key parts and related technologies included in the dual-use items list to the United States will be subject to strict review on a case-by-case basis and no licensing facilitation measures will be applied. This will not put all ordinary walkie-talkies under control, but it will increase the risk of destination review for drone remote controls, data transmission, ground stations and other items.
First distinguish the three customs: China export, domestic SRRC, Taiwan NCC
| system | Answered questions | cannot be mistakenly written as |
|---|---|---|
| China export controls | Whether the goods can be transferred from China to overseas; whether they hit dual-use items, military goods, temporary control, comprehensive control or specific end-user measures. | With/without SRRC. |
| Radio management in China | Whether it can be produced or imported for sale and use in China; whether the operating frequency, power, model approval, sales filing and station license are in compliance. | China export license or Taiwan import license. |
| Import and use in Taiwan | When entering Taiwan, do you need NCC input approval, type certification, self-use cutting, as well as BSMI, customs and radio usage regulations? | China's permission to leave means Taiwan's permission to enter. |
The same walkie-talkie may "generally do not require a dual-use item license for export from China", but "still must be declared to customs when taken out of the country", and "an NCC must be applied for entering Taiwan". All three answers can be true simultaneously.
One-minute check: follow these 6 steps
1Confirm the actual product, not just the store name
Obtain the complete model, specifications, frequency band, transmission power, communication distance, whether it contains encryption, telemetry/remote control functions, and whether it is dedicated to drones, radars, navigation or jamming equipment.
2First check whether it is an ordinary civil communication
Generally, handheld walkie-talkies, Wi-Fi, Bluetooth, mobile phone communications or short-range civilian remote controls usually do not become dual-use items just because they can transmit radio.
3Verbatim comparison of control codes
Focus on checking 5A101 telemetry/remote control ground equipment, 5A002 information security, 6A108 target detection, 7A101–7A106 navigation, 9A012.e controlled drone dedicated communication and 0A903 anti-drone system.
4Check the true end use and end user
You can’t just look at the Taiwan delivery address. If it will be transferred to the military and police, controlled entities, third countries or other actual users, it should be determined based on the true flow.
5Decision on general export, business consulting or licensing
Clear miss: save the judgment data and then take the normal exit. Specifications are unknown or close to description: the exporter from mainland China shall first submit business consultation to the Ministry of Commerce. A clear hit: first apply for an export license for dual-use items, and you will not be allowed to declare for export without obtaining it.
6Also handles carrying/shipping and Taiwan imports
The "List of Restricted Entry and Exit Items" in Order No. 43 of the General Administration of Customs still lists "radio transceivers and communication security machines"; passengers carrying or sending them should declare the facts and confirm with the customs at the place of exit. When entering Taiwan, check the NCC separately.
Radio equipment export classification
"General" in the table below only means that dual-use item permission is usually not required, and does not guarantee that any package will be released; it must still comply with customs declaration, transportation and destination regulations.
| Grading | product or condition | Member screen | Next step |
|---|---|---|---|
| Usually general export | Ordinary civilian walkie-talkies, general Wi-Fi/Bluetooth equipment, general mobile phone communication equipment, and ordinary short-range civilian remote controls. | Out General | Keep specifications, usage, users and flow information; also check customs carrying/delivery and Taiwan NCC. |
| Identification of necessary items | Telemetry equipment, as well as telemetry or remote control ground equipment; may include some UAV remote controls, data transmission, telemetry and ground control stations. | Out of 5A101? | There is no performance threshold and can be simplified by oneself; the exporter is asked to consult or make judgments based on actual functions. |
| Dual-use item license required | Specially used for 9A012.a controlled drones, and the radio range is >50 km, or one station can control >10 drones. | Out 9A012.e | Exporters from mainland China first apply for a license. |
| Dual-use item license required | Civilian anti-UAV electronic interference equipment, interference range >5 km. | Out 0A903.a | Apply for a license first; there are strict restrictions on possession, sale and use in China. |
| Dual-use item license required | A high-power laser with output power >1.5 kW dedicated to anti-UAV systems. | Out 0A903.b | Apply for permission first. |
| Identification of necessary items | Radar equipment and its related electronic devices as target detection electronic devices. | Out of 6A108? | All ranging/obstacle avoidance modules cannot be listed uniformly; they should be judged based on actual use and structure. |
| Judge by performance | Cipher machines, cryptographic cards, encryption VPNs, key management, industry-specific or quantum cryptography devices. | Out of 5A002? | Check the main functions, algorithms, speed, management volume and industry usage. |
| Judge by performance | High-precision accelerometer, gyroscope, stabilization platform, autopilot, navigation processor and target detection altimeter. | Out of 7A1? | Check 7A101–7A106 item by item, and determine directly without fuzzy product names. |
| Military products franchise | Specialized in military communications, military satellite communications, military radar, electronic warfare and communications jamming equipment. | Out of MIL | Ordinary foreign traders are not allowed to export under general trade, and must be handled by those with military product export franchise qualifications. |
| Certain end users are prohibited | Export dual-use items to eight Taiwanese entities listed in Ministry of Commerce Announcement No. 35 of 2025. | Out prohibited | Prohibited in principle; in special circumstances, export operators must apply to the Ministry of Commerce. |
The 6 most easily misjudged control codes
| control code | Checklist Highlights | Correct understanding |
|---|---|---|
5A101 | Telemetry equipment, and telemetry or remotely controlled ground equipment. | The text itself has no range, power or drone-specific prerequisites, and the 2026 catalog does not reference HS; related ground equipment should not be judged as general export on its own. |
5A002 | Specific security chips, cryptographic machines/cards, encrypted VPNs, key management, specialized and quantum cryptography devices. | Regular AES radios don't automatically hit just because they use AES. Categories such as VPN also have conditions such as 10 Gbps, 50,000 tps, 10,000 managed objects, or industry-specific use. |
6A108 | Target detection electronics and components, including radar equipment. | The list excludes related devices integrated on civil aircraft, general aircraft and other civil aircraft; drone-related items are handled in accordance with other provisions of the list. |
7A101–7A106 | Accelerometers with proportional error <0.25%, gyroscopes with drift rate <0.5°/h, as well as stable platforms, autopilots, etc. | It must be judged based on specific indicators and product structure, and all ordinary consumer electronics "with GPS/IMU" cannot be classified. |
9A012.e | Dedicated radio communication for controlled UAVs, visual range >50 km or control of >10 drones from one station. | 50 km is not a universal threshold for all drone remote controls; it must first comply with "Specially used for 9A012.a controlled drones". |
0A903 | Civilian anti-drone interference >5 km, or dedicated laser output >1.5 kW. | Being less than the threshold only means that the code is not hit, but it does not mean that jammers can be freely produced, sold, held or used in China. |
If the product has multiple functions at the same time, all possible codes must be checked separately; a looser product name cannot be selected to cover other controlled functions.
What does the SRRC do?
| situation | Whether it involves SRRC/domestic system | relationship with exports |
|---|---|---|
| Produced in China and sold and used in China | Except for those exempted according to law, apply for model approval of radio transmitting equipment in accordance with regulations, and handle sales registration when selling. | It is a domestic listing requirement, not an export license for dual-use items. |
| Imported walkie-talkies for sale and use in China | The same is done in accordance with the model approval catalog and domestic regulations. | This is China’s “import + domestic use” issue. |
| All products produced in Chinese factories are exported overseas. | The model approval text in Article 16 of Guo Wu Ban [2025] No. 1 and Article 6 of the "Radio Transmitting Equipment Management Regulations" both limit "sales and use within the country/our country." | Export cannot be prohibited just because there is no SRRC; an export control determination still needs to be made. |
| Dedicated/shared/public/water intercoms for use in China | Also look at frequency use licenses, station licenses, equipment technical requirements and markings. Public walkie-talkies are exempt from frequency licenses and station licenses, but the equipment must still comply with regulations. | The equipment is used in Taiwan after export and does not directly apply to frequency bands in China. |
The "List of Restricted Entry and Exit" and the SRRC are two different things. The former still lists "radio transceivers and communication security machines" as restricted items for export, and will especially appear in the supervision of passenger baggage, carrying and delivery; the latter deals with sales and use within China. Neither can be reduced to "no exports without SRRC".
How to make preliminary judgments on common products
| Product condition | preliminary results | Next step for membership |
|---|---|---|
| General 150/400 MHz civilian handheld radio, voice communications, no telemetry ground station, radar or jamming capabilities | Dual-use permit is usually not required | Confirm that it is not military supplies or communications security equipment; keep the specifications and check the carrying/delivery with Taiwan NCC. |
| Commercial radios with AES‑256 voice encryption | Cannot judge 5A002 based on AES alone | Confirm the product's main functions, industry uses and whether it is a cryptographic device listed on the list. |
| UAV remote control, data transmission, telemetry or ground control station | Check 5A101/9A012.e first | Get instructions on communication distance, number of machines controlled by one station, applicable drones and telemetry/remote control functions. |
| General household Wi‑Fi router or Bluetooth headset | Usually general exit | When it is for normal civilian use and does not have a managed encryption function, a dual-use item license is usually not required; Taiwan may still require an NCC. |
| Encrypted VPN device, advertised 12 Gbps encrypted communication rate | Possible hit 5A002.c | The exporter shall check the algorithm, main functions and complete performance before applying or consulting. |
| Anti-drone electronic jammer, marked 8 km jamming range | Hit 0A903.a | Dual-use items are not allowed to be exported without an export license; domestic sales and possession are also high risks. |
| Specialized military tactical radio, electronic warfare or communications jamming equipment | Military product program | It can only be handled by operators with exclusive military product export qualifications in accordance with the law. |
Check of models on sale in China’s e-commerce (verification date: 2026-08-23)
The following is a multi-group review that simultaneously compares Chinese e-commerce sales pages, original factory specifications and the 2026 control catalog. The e-commerce page only proves that it has been on sale, and the parameters are mainly based on the original manufacturer's information; "civilian use, full frequency band, 5000 kilometers, high power, confidentiality" written in the store cannot replace the export determination. Price, inventory and SKU will change, and the link must be reopened for confirmation before shipment.
China does not have an official “white list of exportable models” or “blacklist of prohibited models”. The following green light only means that the published standard specifications do not match the listing description; the yellow light means that the product cannot be released based on the product name alone; the red light means that the supplier's public parameters have met the listing description, and permission must be obtained first. Regulated end-user, military use, or other comprehensive regulatory situations can still change the conclusion of any column.
A. The preliminary judgment of public standard specifications can be used for general export.
| Brand/Model | Reveal key specifications | Preliminary export results | On sale/Original evidence |
|---|---|---|---|
| Motorola TALKABOUT T42 (China version) | 409 MHz, 0.5 W, 20 channels, normal short range voice. | Out of General No telemetry, radar, or dedicated cryptographic features seen. | Jingdong · Original factory |
| Motorola V168（V168-G6B-4） | 430–440 MHz, 4/1 W, analog FM, 16 channels. | Out General Purely commercial voice version. | JD · Original PDF |
| BAOFENG BF-888S Standard version | UHF 400–470 MHz, less than 5 W, 16 channels, analog FM. | Out General Do not apply to SKUs modified by the seller. | JD · Original |
| BAOFENG UV-5R Standard／25th | 136–174, 400–520 MHz, 5/1 W, analog, 128 channels. | General "GPS/DMR/Positioning Upgraded Version" is subject to separate judgment. | JD · Original |
| QUANSHENG UV-K5 | VHF/UHF dual-band, up to 5 W, 200 channels; aviation band is the receiving function. | Out General "Full band" does not mean that the entire band can be transmitted. | JD · Specification cross-check |
| Motorola XiR C1200 | DMR/Analog, VHF/UHF depending on version, VHF 5 W, UHF 4 W. | Out General Lock frequency band, firmware and options. | Jingdong · Original factory |
| Hytera BD500 | DMR/Analog, 136–174 or 400–470 MHz, VHF 5 W/UHF 4 W. | Out General Standard business voice version. | JD · original |
| Hytera BP510 | DMR/analog, 256 channels, VHF/UHF, industry hardware codes are not listed on the standard page. | Out General DMR itself is not a reason for listing. | Jingdong · Original |
| Kirisun PT570 | 400–470 MHz, 4 W, 16 channels, analog voice. | Out of General No positioning or dedicated password functions. | Jingdong · Original PDF |
| Kirisun DP405 | DMR/Analog, VHF/UHF, 40-bit ARC voice encryption. | Out General 40-bit ARC will not hit 5A002 alone. | JD · Original |
| Hytera PNC360 (normal PoC voice version) | 4G public network PTT, RTOS, GPS/Beidou are optional. | Out General Normal PoC or general positioning is not equal to 5A101/7A1. | JD · Original PDF |
| Kirisun T60 | 4G PoC, Wi-Fi, GPS/Beidou/GLONASS, general remote scheduling. | Out General Position scheduling for ordinary personnel is not equal to high-precision navigation. | JD · Original |
| Hytera P50 Pro (standard PoC version) | New products in 2025, LTE PoC, Wi-Fi 5, NFC, fast group establishment. | General Public security/law enforcement special encrypted version must be judged separately. | JD · Original release |
B. Cannot directly mark "General Export": obtain complete SKU and item conclusions first
| Model/Configuration | Why is it a yellow light? | Control code should be checked | On sale/Original evidence |
|---|---|---|---|
| Xiaomi Walkie-Talkie 2S (XMDJJ04FY) | 430–440 MHz, 4 W; the manual shows that devices on the same frequency can exchange location information via radio, not just local positioning on the mobile phone. | 5A101? Confirm the coordinate data transmission and purpose first. | Jingdong · Instructions |
| Motorola XiR P8668i/explosion-proof version | GPS, Bluetooth, 40-bit and AES-256 may vary depending on actual licensing and options. | 5A002? Get precise SKUs, AES entitlements and end users. | JD · original |
| Hytera HP780 CQST | Location, end-to-end encryption, and other security features are available by version. | 5A002? The standard version and the industry password version are judged separately. | JD · original |
| Hytera PD780G | GPS/Beidou, AES/ARC4, and equipped with "Ministry of Public Security Hardware Encryption" configuration. | 5A002.e? Special password versions for public security and other industries are not allowed to be released directly. | JD · Original |
| Hytera PNC560 | 5G secure terminal, dual-domain isolation, multi-layer software and hardware encryption, and Beidou-3 optional. | 5A002.e? Confirm whether the password is configured for a specific industry. | JD · Original |
| Hytera PDC580 | 4G+DMR dual-mode, positioning, PoC/DMR gateway; versions and uses vary greatly. | 5A002? Confirm password configuration and end use. | JD · original |
| Kirisun DP810／DP815 | PDT/DMR, 256-bit voice encryption, hardware encryption from the Ministry of Public Security, GPS/Beidou. | 5A002.e? Do not mark general before confirming the precise configuration. | Jingdong · Original PDF |
| Caltta PH790 (including U(3) encrypted version) | The original factory is a DMR/PDT private network machine, not the public network machine written by some sellers; the encrypted version configuration has not been fully disclosed. | 5A002? Subject to the original SKU and technical documents. | JD · Original PDF |
| DJI RC 2 | O4 UAV remote control/image transmission ground equipment, the public distance is up to 20 km depending on the region. | 5A101? 20 km does not mean an automatic hit to 9A012.e. | JD · Original |
| DJI Air 3S/RC-N3 set | RC-N3 transmits real-time flight status, remote control and images, and belongs to the boundary of UAV ground equipment. | 5A101? The exporter will first make the item identification. | JD · Original Manufacturer Mall |
| DJI RC Plus／RC Plus 2 | Compatible with M30/M350/M400/Matrice 4 and other industrial drones, with remote control, digital transmission and image transmission. | 5A101? Check 9A012.e again depending on the platform. | JD · Original specifications |
| SIYI HM30 | 20 km, 1080p, MAVLink telemetry, OSD, SBUS/PWM. | 5A101? Does not meet the 50 km condition of 9A012.e. | Original manufacturer mall/specifications |
| SIYI MK32 | 15 km, dual-channel high-definition image transmission, Ethernet/RC I/O, and explicit handheld ground station. | 5A101? You cannot press the ordinary remote control to export directly. | Original manufacturer mall/specifications |
| SIYI UniRC 7 Pro | 40 km, 4K image transmission, AES, ground station for UAV/UGV/USV. | 5A101? 40 km itself is still less than 9A012.e. | Original manufacturer mall/specifications |
| YANGDA VideoPass N60 | UAV dedicated imaging, telemetry and command link, publicly known as 60 km, AES-128. | 5A101?/9A012.e conditional expression You must first confirm whether the mounting platform is 9A012.a. | Brand supply page |
| Dahua ITC1652-SU2F-GQE-C2R1-IRL8ZF1640 | Smart transportation equipment has a built-in 24 GHz millimeter wave radar that can track multiple targets. | 6A108.a? The Ministry of Commerce’s requirements for traffic radars are judged based on performance and use. | Original specifications · Reply from the Ministry of Commerce |
C. The public parameters have met the description of the listing: it cannot be exported as ordinary commodities before obtaining the license.
| Supply model | Supplier public specifications | control results | evidence |
|---|---|---|---|
| J03-6K06 Anti-UAV Jammer | The supply page states that there are five frequency bands and an interference distance of 6 km. | 0A903.a/Permission required Because the public interference range is greater than 5 km. | China Made Network Supply Page |
| YFR-03B X-band anti-drone radar | 360° target detection radar, supply page says it can detect the Phantom 4 up to 7 km. | 6A108.a/Licensing required The product itself is a target detection radar. | China Manufacturing Network Supply Page |
| SIYI N7 Autopilot Flight Controller | The official store clearly states that it is an autopilot flight controller for Drone/UAV. | 7A103.b/Permission required The list does not set additional performance thresholds for drone autopilots. | Original manufacturer mall/specifications |
| Holybro Pixhawk 6X Rev8 | It is now on sale at the Shenzhen brand mall and is clearly labeled UAV flight controller/autopilot. | 7A103.b/Permission required Export can only be obtained after obtaining a dual-use item license. | Original manufacturer store/specifications |
The red light in the above table indicates that there is a legal licensing process before exporting; only when the license is required but is not obtained, falsely reports parameters, conceals the end user, or violates prohibitive measures, it is non-compliant export. It is still possible to legally export controlled items by obtaining a valid license and making customs declarations in accordance with the contents of the license.
The values of J03-6K06 and YFR-03B are from the supplier’s disclosure page and are not identified by the competent authority. Formal export requires obtaining the catalog, BOM, test report and actual shipping version, and the mainland Chinese exporter applies for a license or submits business consultation according to the list.
If DJI, SIYI, YANGDA and other ground equipment are ultimately determined to be included in dual-use items, export to the United States will also be subject to strict case-by-case review in the Ministry of Commerce’s Announcement No. 34 of 2026, and no licensing facilitation measures will be used.
What do I need to apply for? Who applies?
Applicants for dual-use item licenses are Mainland China export operators. Taiwanese buyers and container warehouses cannot obtain Chinese licenses on behalf of exporters, but must provide real end-user and usage information.
| situation | Required documents/actions |
|---|---|
| It is clear that it is not a dual-use item | Keep original factory specifications, product photos, models, functional descriptions, contracts, actual uses, end users and flow information; declare truthfully to customs in accordance with the law. |
| Unable to determine whether hit | The exporter shall submit a business consultation on dual-use items through the Ministry of Commerce's online government affairs hall, explaining the performance indicators, main uses and reasons for uncertainty. The reply will be based on the submitted materials, and the actual shipment must still be identified again based on the actual configuration. |
| Unambiguous hit on dual-use item | The exporter applies for a license in the business system of the Ministry of Commerce and submits an application form, contract/agreement, technical description or test report, end-user and end-use certificate, end-user introduction and identity information, etc. |
| Customs raises questions about dual-use items | According to Announcement No. 123 of 2025 of the General Administration of Customs, in principle, paper customs declaration forms, contracts, performance and use descriptions and other materials with official seals must be submitted within 7 working days from receipt of the notice of challenge; no release will be allowed during the questioning period. |
| Passengers carrying or sending radio transceivers out of the country | Declare to the customs truthfully; since Order No. 43 is listed as a restricted export item, the specific release or competent documents should be confirmed with the customs at the actual exit port before shipment. There is no need to use an SRRC certificate to pretend to be an export permit. |
The Ministry of Commerce has made it clear that if a dual-use item fails to submit the license documents for inspection during customs declaration, it constitutes an unauthorized export; obtaining a license only after customs declaration does not change the nature of the violation.
The Ministry of Commerce’s business consultation reply is based on the written information submitted by the exporter. After changing the model, firmware, power, function, purpose, user or flow, it must be re-identified according to the actual export situation.
Send to Taiwan: The eight entities and the NCC should be looked at separately
The Ministry of Commerce's Announcement No. 35 of 2025 prohibits the export of dual-use items to eight Taiwanese entities, and ongoing relevant transactions should be stopped; if export is really necessary under special circumstances, the export operator shall apply to the Ministry of Commerce. This is not a blanket embargo on all Taiwanese recipients, nor on all common radios.
- 1. Hanxiang Aviation Industry Co., Ltd.
- 2. Jingwei Aerospace Technology Company
- 3. Zhongshan Academy of Sciences
- 4. Zhongshuo Technology Co., Ltd.
- 5. international shipbuilding co., ltd.
- 6. CITIC Shipbuilding Co., Ltd.
- 7. longdeok shipbuilding industry co., ltd.
- 8. attack and defense co., ltd.
If a Hong Kong trader, Taiwanese purchasing agent or other company only receives the goods as an intermediate, the actual end users are still the above eight companies, and the end user determination cannot be changed due to the change of hands.
Walkie-talkies, Wi-Fi, Bluetooth, mobile communications and other radio frequency equipment entering Taiwan must be subject to NCC's import approval, type certification or self-use cut-off regulations. A Chinese export license is not a substitute for a Taiwan NCC document.
Before members place an order, please ask the seller for these 9 items
- Complete brand, model, hardware version, firmware version and product photos
- Working frequency band, transmit power, modulation method and maximum communication distance
- Whether it has telemetry, remote control, digital transmission, image transmission or ground control station functions
- Whether it is specially used for a specific drone; applicable drone models and the maximum number of drones controlled at one station
- Whether encryption is included; algorithm, main functions, encryption rate, signature rate or number of key management
- Whether it has radar, target detection, navigation, inertial or jamming/anti-drone functions
- The actual export companies in China and their basis for item determination or business consultation
- Real end user, actual purpose, place of use and whether it will be resold or transferred
- On the Taiwan side, it is expected to be handled through commercial import, personal use or NCC import approval.
"Please provide the frequency band, transmit power, communication distance, telemetry/remote control function, encryption specifications and main uses of the actual shipped version of this model, and confirm whether it involves Chinese dual-use items 5A101,5A002,6A108,7A1,9A012.e or 0A903. If it cannot be determined, the actual export company should first submit a business consultation to the Ministry of Commerce. Do not use SRRC The certificate replaces the export determination. "
FAQ
Can walkie-talkies without SRRC be exported from China?
You cannot judge based on SRRC alone. The model approval requirements of Guo Wu Ban [2025] No. 1 and the "Radio Transmitting Equipment Management Regulations" are for equipment sold and used in China. At the export end, dual-use items, military items, end-use/users, customs item declarations and destination regulations must still be checked separately.
Are ordinary civilian walkie-talkies dual-use items?
Ordinary voice communication walkie-talkies do not automatically qualify as dual-use items just because they can send and receive radios. If it has other functions such as telemetry/remote control ground equipment, high-performance cryptography, radar, navigation, jamming, or military special design, it is necessary to further check the relevant control codes.
Does it have to be 5A002 if it has AES‑256 encryption?
no. 5A002Judged based on equipment type, main functions, industry usage and performance. A regular walkie-talkie using AES does not automatically equate to a cryptographic machine, cryptographic card, encrypted VPN, key management or dedicated cryptographic device in the list.
Is drone remote control restricted only if it exceeds 50 km?
It cannot be judged this way. 9A012.e's 50 km premise is that the equipment is specifically used for 9A012.a controlled drones; on the other hand, telemetry equipment or telemetry/remote control ground equipment may also involve 5A101 that does not have a distance threshold, so ordinary drone ground equipment should be identified first.
Customs Order No. 43 lists "radio transceivers", does it mean that all exports are prohibited?
No. "Restriction" does not mean "forbidden", nor does it mean that all products require SRRC. This item list will affect the supervision of passengers' carrying, luggage and delivery; whether commercial goods require dual-use item licenses will still be determined based on the export control list, technical conditions, uses and users.
If I don’t see dual-use items in the HS Code, can I export them directly?
No. The Ministry of Commerce explained that the customs commodity number is not the basis for determining dual-use items; even if the reference HS is not listed in the catalog, as long as it meets the list description, it must still be licensed in accordance with the law.
Who applies for an export license for dual-use items from China?
Export operators from mainland China apply through the Ministry of Commerce system. Taiwanese buyers provide real end users, end uses and usage information; the container warehouse cannot replace the exporter to obtain the license.
Can ordinary walkie-talkies be used directly after being shipped to Taiwan?
Not necessarily. China is only allowed to complete the export end; importing to Taiwan requires NCC input approval, type certification or self-use cutting according to product level, quantity and purpose. The actual frequency used and radio station settings must also comply with Taiwan regulations.
Can I definitely export without making a list?
It is still necessary to check the comprehensive control of Article 12 of the Export Control Law: If the exporting party knows, should know, or is notified that the items may endanger China's national security and interests, be used for weapons of mass destruction and their delivery vehicles, or terrorism, they should still apply for a license.
Official sources and verified versions
This article is based on the original Chinese official text; C114 is only used as a source of policy interpretation and cannot replace announcements from the Ministry of Industry and Information Technology and the Ministry of Commerce.
- State Radio Office State Non-commercial Affairs Office [2025] No. 1: Domestic management of 150 MHz and 400 MHz walkie-talkies
- "Radio Transmission Equipment Management Regulations" (Ministry of Industry and Information Technology Order No. 57)
- Announcement No. 51 of 2024 of the Ministry of Commerce and others: "The Export Control List of Dual-use Items of the People's Republic of China"
- Official PDF of the 2026 "Catalogue for the Administration of Import and Export Licenses for Dual-Use Items and Technologies"
- Ministry of Commerce: HS Code is not the basis for determining dual-use items
- "Export Control Law of the People's Republic of China"
- "Regulations of the People's Republic of China on Export Control of Dual-Use Items" (State Council Order No. 792)
- Ministry of Commerce: Dual-use Items Export License Application Filling Guide and Business Consultation
- General Administration of Customs Announcement No. 123 of 2025: Customs Question on Export Control of Dual-Use Items
- General Administration of Customs Order No. 43: "List of Prohibited and Restricted Entry and Exit Items"
- Ministry of Commerce Announcement No. 35 of 2025: Export Control List of Eight Taiwan Entities
- Ministry of Commerce 2026-07-03 Official reply to questions about 9A012.e
- Ministry of Commerce Announcement No. 34 of 2026: Strict review of exports of drone-related dual-use items to the United States on a case-by-case basis
- China Export Control Information Network: Dual-use item query results are for reference only and shall not be used as a basis for applying for a license.
- Ministry of Industry and Information Technology: Civilian UAV radio countermeasures equipment may not be developed, produced, sold, imported, installed or used without approval
This article is a compilation of general regulatory information and is not an item identification or legal opinion based on individual cases by the Ministry of Commerce, Customs or the Ministry of Industry and Information Technology. The hardware, firmware, functions, performance, uses, end users and flow directions of radio equipment are different, and the export conclusions may be different. Before official shipment, the actual export operators in mainland China should handle the matter according to the latest list, announcements and responses from the competent authorities.
We need to check next step
Clearing China export controls is only the first step
For radios entering Taiwan, also check NCC import approval, type certification, personal-use quantity limits and permitted operating frequencies.
Then check Taiwan NCC regulations