Important Notice to Our Valued Customers and Partners
ZANVISION is committed to full compliance with all applicable export control laws and regulations of the People's Republic of China. In accordance with recent regulatory developments, we wish to inform our customers about important requirements that may apply when purchasing certain ZANVISION products.
Legal Definition of Dual-Use Items Under Chinese Law
The term "dual-use items" (Dual-Use Items) is defined in Chinese law through two key legislative instruments. We present the original statutory language alongside its English translation below for the reference of our international customers.
Export Control Law of the People's Republic of China — Article 2 (Adopted October 17, 2020; Effective December 1, 2020)
中文原文：
本法所称Dual-Use Items，是指既有民事用途，又有军事用途或者有助于提升军事潜力，特别是可以用于设计、开发、生产或者使用大规模杀伤性武器及其运载工具的货物、技术和服务，包括相关的技术资料等数据。
Official English Translation (NPC):
For the purposes of this Law, "dual-use items" means goods, technologies, and services that may be used either for civil purposes or for military purposes or to contribute to an increase in military potential, especially to design, develop, produce or use weapons of mass destruction and their means of delivery.
Regulations on the Export Control of Dual-Use Items — Article 2 (Adopted September 18, 2024; Effective December 1, 2024; State Council Decree No. 792)
中文原文：
本条例所称Dual-Use Items，是指既有民事用途，又有军事用途或者有助于提升军事潜力，特别是可以用于设计、开发、生产或者使用大规模杀伤性武器及其运载工具的货物、技术和服务，包括相关的技术资料等数据。
English Translation (CSET):
As used in this Regulation, "dual-use items" shall mean goods, technologies, and services that have civilian uses and also have military uses or contribute to the enhancement of military potential, in particular those that can be used for the design, development, production, or use of weapons of mass destruction (WMD) and their means of delivery, including relevant technical reference and other data.
Key Interpretive Note: The 2024 Regulations (Article 2, Paragraph 3) further clarify that "export control" refers to measures adopted by the State to prohibit or restrict the transfer of dual-use items from within the territory of the People's Republic of China to areas outside the PRC, as well as the provision of dual-use items by Chinese citizens, legal persons, and organizations without legal person status to foreign organizations and individuals. This includes both trade-related export and external transfer through donation, exhibition, cooperation, assistance, and other means.
Technical Parameters & Scope of Control for Infrared Imaging Equipment
The Dual-Use Items Export Control List of the People's Republic of China (MOFCOM Announcement No. 51 of 2024, effective December 1, 2024) places infrared imaging equipment under control when such equipment meets the following technical specifications and is intended as a payload for unmanned aerial vehicles or unmanned airships. The controlling entry is Category 9, Item 9A012.c (Aerospace and Propulsion — Systems, Equipment and Components).
Original Text of Entry 9A012.c — Dual-Use Items Export Control List (Unofficial Translation)
中文原文（9A012.c）：
c．满足一定技术指标的专门用于特定"无人驾驶航空器"或"无人驾驶飞艇"的"载荷"，包括"红外成像设备"、"合成孔径雷达"、"目标指示激光器"、惯性测量设备：
1．具有以下两种特性的"红外成像设备"：
a．波长范围 780～30000 nm；
b．"瞬时视场角"（IFOV）小于 2.5 mrad；
English Translation (9A012.c):
c. "Payloads" meeting certain technical specifications, specially designed for specific "unmanned aerial vehicles" or "unmanned airships," including "infrared imaging equipment," "synthetic aperture radar," "target designation lasers," and inertial measurement equipment:
1. "Infrared imaging equipment" possessing both of the following characteristics:
a. Wavelength range 780–30,000 nm;
b. "Instantaneous Field of View" (IFOV) less than 2.5 mrad.
Key Technical Definitions (Technical Notes to 9A012)
中文原文（技术说明）：
1．"红外成像设备"是一种利用物体发射的红外辐射来形成图像的探测设备，广泛应用于夜视、热成像、搜索与救援等领域。
4．"瞬时视场角"是指探测器在某一瞬间所能覆盖的视场角度，它决定了探测器的空间分辨率。
English Translation (Technical Notes):
1. "Infrared imaging equipment" refers to a detection device that uses infrared radiation emitted by objects to form images, widely used in fields such as night vision, thermal imaging, search and rescue.
4. "Instantaneous Field of View" (IFOV) refers to the angular field of view that a detector can cover at any given instant; it determines the spatial resolution of the detector.
Scope of Application — When Does the Control Apply?
Regulatory Scope：Entry 9A012.c controls infrared imaging equipment only when the equipment is (1) specifically designed as a payload for certain unmanned aerial vehicles or unmanned airships AND (2) meets both of the technical thresholds listed above (wavelength range 780–30,000 nm and IFOV less than 2.5 mrad).
Scope Clarification: Standalone infrared/thermal imaging cameras that are not designed as drone/airship payloads are not captured by Entry 9A012.c. However, all products should still be assessed against the full control list, as other entries may apply depending on the specific product configuration, end-use, and end-user. The dual-use determination ultimately requires a holistic assessment of the product's technical specifications, intended use, and destination.
This entry aligns with the broader framework established by the Export Control Law (2020) and the Dual-Use Items Export Control Regulations (2024). Customers are strongly advised to conduct their own compliance assessment or consult qualified export control counsel.
Products That May Require Export Licensing
Based on the Export Control Law of the People's Republic of China (effective December 1, 2020), the Regulations on the Export Control of Dual-Use Items (effective December 1, 2024), the Dual-Use Items Export Control List (2024, updated 2026), and the General Administration of Customs Announcement No. 78 of 2026 (effective June 30, 2026), the following categories of ZANVISION products may be classified as dual-use items subject to export licensing requirements:
1. LWIR Thermal Imaging Modules
Uncooled VOx microbolometer-based thermal camera cores with resolutions of 640x512 or 1280x1024 pixels, operating in the 8-14 um long-wave infrared spectral band. These products, particularly when configured for integration into unmanned aerial vehicle (UAV) payload systems, may fall within the scope of items controlled under the Dual-Use Items Export Control List.
2. Electro-Optical / Infrared (EO/IR) Multi-Sensor Systems
Gyro-stabilized multi-sensor PTZ platforms that integrate thermal and visible-spectrum imaging, including gimbal pods designed for UAV or unmanned ground vehicle (UGV) payload applications (e.g., the ZanPod series and Aurora EO/IR series).
3. Thermal Lenses and Infrared Optical Assemblies
Specialized LWIR optical lenses and lens assemblies designed for use with thermal imaging systems, which may be controlled as components or parts of dual-use items.
4. High-Performance VIS/NIR Zoom Block Cameras
Visible-spectrum zoom camera modules with extended zoom ratios (52x-55x), global shutter sensors, and ultra-low-light (0.0001 Lux Starlight) capability, where the intended integration into UAV or surveillance systems may trigger export control requirements.
5. Thermal Scopes and Sights
Thermal imaging-based aiming and observation devices.
Please note: This list is not exhaustive. The determination of whether a specific ZANVISION product requires an export license depends on the product's technical specifications, the intended end-use, the end-user, and the destination country. We strongly recommend that customers consult with their legal and trade compliance advisors to assess their specific obligations.
What This Means for You - Required Documentation
Pursuant to Article 15 of the Export Control Law of the People's Republic of China, for products that are determined to require an export license, the exporter (ZANVISION) must submit to the state export control authorities a certificate concerning the end-user and end-use. This certificate must be issued by the end user or the relevant government agency of the country or region where the end user is located.
Specifically, the end-user customer is required to provide:
1. End-User and End-Use Certificate - A legally binding document, in the format prescribed by the Ministry of Commerce of the People's Republic of China (MOFCOM), signed and stamped by the end-user company (corporate edition) or certified by the competent government authority of the importing country (government edition). The certificate must include:
- Full legal name and registered address of the end-user entity
- Detailed description of the commodity being purchased
- Contract or purchase order reference number
- Specific end-use description (civilian/commercial application)
- A binding commitment that the products will not be used for any purpose related to weapons of mass destruction or their delivery systems
- A binding commitment that the products will not be transferred to any third party without prior consent of the Chinese government
2. End-Use Statement / Technical Use Description - A detailed description of the intended civilian or commercial application of the products.
3. Company Profile / Business Registration - Basic corporate information of the end-user entity.
4. Additional documentation as may be required by MOFCOM on a case-by-case basis.
Legal Obligations and Penalties
Under Article 16 of the Export Control Law, the end user of a controlled item shall undertake not to change the end use of the relevant controlled item or transfer it to any third party without consent of the state export control authorities. Where an exporter or importer discovers that there may be a change of end user or end use, they shall immediately report to the state export control authorities.
Violations of export control laws and regulations may result in severe consequences, including but not limited to:
- Administrative fines and confiscation of illegal proceeds
- Suspension or revocation of import/export privileges
- Placement on the MOFCOM Watch List or Control List
- Criminal liability in cases of serious violations
- Goods being detained, seized, or returned at the border
Our Commitment
ZANVISION is dedicated to:
- Conducting export control compliance screening for every international order
- Assisting customers with the preparation and submission of required documentation
- Protecting the confidentiality of all customer-provided information - end-user certificates and related documents are used solely for export license applications and are stored securely with access limited to designated compliance personnel
- Processing license applications efficiently to minimize disruption to delivery schedules
- Maintaining transparent communication with customers throughout the compliance process
Recommended Timeline
Export license applications for dual-use items typically require 4-8 weeks for processing by MOFCOM. We recommend that customers:
- Before placing an order: Consult with ZANVISION's sales team to determine whether the intended products may require export licensing.
- At order placement: Prepare and submit the End-User and End-Use Certificate along with supporting documentation.
- Allow sufficient lead time: Factor the license processing timeline into project planning and delivery schedules.
Contact Us
For questions about export control compliance, to request the official End-User and End-Use Certificate template, or to initiate a compliance review for your intended purchase, please contact our export compliance team:
Email: sales@zanvisiontech.com
References and Legal Basis
- Export Control Law of the People's Republic of China (adopted October 17, 2020, effective December 1, 2020) - NPC Official English Text, Articles 12, 14, 15, 16, 19, 21, 34-44
- Regulations of the People's Republic of China on the Export Control of Dual-Use Items (adopted September 18, 2024, effective December 1, 2024) - State Council Official Release
- Dual-Use Items Export Control List of the People's Republic of China (MOFCOM Announcement No. 51 of 2024, effective December 1, 2024) - MOFCOM
- 2026 Catalogue of Dual-Use Items and Technologies for Import and Export License Management (MOFCOM & GACC, December 31, 2025, effective January 1, 2026) - MOFCOM
- GACC Announcement No. 78 of 2026 on Regulating Export Declaration for Unmanned Aircraft and Related Items (June 9, 2026, effective June 30, 2026) - GACC
- China's Export Controls - State Council White Paper (December 29, 2021) - White Paper Full Text
This advisory is provided for informational purposes only and does not constitute legal advice. Customers are responsible for understanding and complying with all applicable export control laws and regulations. ZANVISION reserves the right to decline or delay any order that, in its reasonable assessment, may raise export control compliance concerns.
