About "Export Control Law of the People’s Republic of China"

[wanaki]

Recently announced announcements of "Import License List" and "Export Control List for Commercial Encryption"
Are Nordic products fall under the "security chip" section of the Export List?

Reference
www.pillsburylaw.com/.../import-export-control-license-lists-commercial-encryption.html
www.glo.com.cn/.../1555021531.html

[Øyvind]

Hello,

My apologies for the late reply. Due to Christmas holidays our technical support team is lower staffed, and the response time will be longer. Also, most of our R&D our out of office until January 4th. We apologize for any inconvenience this may cause.

I don't have an answer at the moment, but have forwarded for an answer. You can ask your local RSM if you need a quicker answer. 

Kind regards,
Øyvind

[Øyvind]

Hello,

Here is the response from our Quality Department:

Apologies for the delay on this request due to Christmas holidays. 

Nordic SiP is the only Nordic product that should be evaluated for the new China’s export control law since it is manufactured in China. The product is a mass market product to be used in mass market applications meeting the licence exemption according US export control law. As the link you provided also states, similar to US export control law, China’s new Export Control Law and Encryption Announcement includes a mass-market exception too. According to Article 28 of the Encryption Law, the commercial encryption contained in or used for mass-market consumer products will not be subject to control upon export from or import to Mainland China.

However there is no clear definition of what items would qualify for the mass-market exception released yet, as we investigated with our supplier in China, the product is not within the scope. This might change if Chinese provides information about the mass market exemption. 

BR,

Nasrin
(Compliance Officer)