A Shenzhen electronics company planned to export a batch of high-precision gyroscopes to Southeast Asian customers for use in industrial drones. The company believed that the product was an ordinary electronic component and did not apply for a dual-use item export license. During customs declaration, the system flagged a risk because the product parameters were close to controlled standards.
Customs required the company to provide the basis for determining the relevant item under the Dual-Use Items Export Control List. When the company compared the list on its own, it found that the gyroscope's precision indicator (bias stability) might reach the control threshold (reference value: bias stability better than 0.05 degrees/hour), but it was uncertain whether it fell within the controlled scope. If it were determined to be a controlled item without a license having been obtained, the company would face administrative penalties or even criminal liability.
The Shuwang Testing and Certification Platform organized technical experts to check the product's technical parameters item by item and made a preliminary determination based on the specific indicators for gyroscopes in the Dual-Use Items Export Control List (such as bias stability and scale factor nonlinearity). The platform coordinated with a partner laboratory to conduct supplementary testing of the gyroscope, obtain accurate performance data, and issue a test report as the basis for determination. The platform assisted the company in submitting a consultation letter to the national export control administration department to confirm whether the product was a controlled item. At the same time, it guided the company in preparing application materials for a dual-use item export license (such as end-user certificates and internal compliance systems). Based on the consultation results, the platform helped the company improve its internal export control compliance process and establish an item classification ledger.
After testing and official consultation, it was confirmed that the gyroscope did not meet the control standards and no license application was required. However, because the company had not conducted a compliance review in advance, the goods were stranded at the port for 10 days, incurring additional costs of about 15,000 yuan. The company subsequently established an internal review mechanism for export control.
Before exporting products with high-tech parameters, item classification must be carried out against the Dual-Use Items Export Control List, and professional institutions should be used for testing and consultation when necessary. Dual-use item compliance is not only about license applications; an internal compliance system should also be established to avoid legal risks caused by classification errors.