Can my China-based company export dual-use sensors to Europe without breaching sanctions rules?

We can help you navigate the export‑control and sanctions compliance for shipping your industrial sensors from Shenzhen to Europe. First, run a dual-screening of the freight forwarder, the named European buyer and the ultimate end‑user against all relevant sanctions lists (EU Consolidated List, UK Sanctions List, U.S. OFAC SDN/SDGT‑1, UN Sanctions List and any Chinese “dual‑use” export‑control lists) and request a signed end‑user certificate that confirms the final customer is not a listed entity and that the goods will not be re‑export to a prohibited destination. Next, determine the export‑control classification of your sensors (e.g., under the EU Dual‑Use Regulation EN 989 or the Chinese “Export Control Law” – many sensor technologies fall under ECCN 5A991 or similar) and, if the classification requires a licence, apply for an export licence from the Chinese Ministry of Commerce (or, if your components contain U.S. origin content above the de minimis threshold, obtain a BIS EAR licence or a U.S. OFAC licence). Finally, incorporate the compliance checks into your sales contract (include warranty that the buyer will not transfer the items to a sanctioned party) and retain all due‑diligence records for at least five years in case of an audit.

Our headquarters are in Thailand, and our compliance team can provide a full sanctions‑screening service, classification assistance, licence‑application support and contract‑clause drafting to ensure your shipments meet both Chinese export‑control rules and EU sanctions requirements. Let us know if you would like a detailed checklist or a quotation for a turnkey compliance package—we’re ready to help you ship safely and legally.

Sincerely,
Ascendence International Consulting

As Chinese attorney practicing many year in export compliance, we advise that in legal documents such as international sales contracts and technology licensing agreements, add a dedicated clause on 'Export Control and National Security Compliance'. It is clearly stipulated that if the performance of the contract is prevented due to reasons not attributable to the exporter, such as national security review or changes in export control policies, the exporter has the right to delay performance or terminate the contract and be exempted from corresponding liability for breach of contract. At the same time, it is necessary to establish a review that goes far beyond the superficial display of international sanctions compliance lists, but to upgrade it to a comprehensive and wide-ranging in-depth review and always ensure export compliance.