China Reintroduces Export License Controls On Steel Products

The new regulation adds approximately 300 steel products (classified under 10-digit HS codes) to the Catalogue of Goods Subject to Export License Administration (2025). Covered products span Chapters 72 (iron and steel) and 73 (articles of iron or steel) of the Harmonized System, effectively covering the vast majority of steel materials, from raw inputs to finished products.

For the seamless tube sector in particular, the policy is especially far-reaching. A total of 13 categories of seamless pipe products, covering 37 HS codes, have been included in the control list. This essentially brings virtually all seamless tube exports under license administration.

Application Requirements

To obtain an export license for covered steel products, exporters must submit:

A valid export sales contract; and

A product quality inspection certificate issued by the manufacturer.

The license is issued by the Ministry of Commerce or its authorized provincial-level (and certain sub-provincial city-level) commerce authorities. The application process is conducted online through the Ministry of Commerce's Unified Business Platform . Once approved, an electronic license is generated and automatically transmitted to Customs, enabling the exporter to proceed with customs clearance

Impact on Tube Exporters

1. New Administrative Burden

Exporting covered tube products now requires an additional procedural step. Since the license is a statutory prerequisite, failure to obtain it will result in goods being denied customs clearance.

2. Increased Compliance Risk

With 300 HS codes now under control, incorrect classification poses a serious risk. Misdeclaring a controlled product as uncontrolled can result in fines of 5% to 30% of the goods' value for affecting license administration. Even "no-license arrival" - shipping without a license due to procedural delays - can incur fines of up to 30% of the goods' value.

3. Industry Consolidation

Exporters unable to meet the new quality documentation and licensing requirements may be forced to exit the export market or redirect products to domestic sales. This is expected to accelerate industry consolidation, with weaker players being phased out.

4. Short-term "Rush" vs. Medium-term Slowdown

In the period immediately before the policy took effect, some exporters rushed to ship ahead of the deadline. In the medium term, however, as companies become familiar with the new procedures, export volumes may moderate