According to the "Export Control List of Dual Use Items of the People's Republic of China" implemented from December 1, 2024, and the General
Administration of Customs Announcement No. 77 of 2026, the compliance certificate for dual-use items of laser engraving machines should include
the following core contents:
1、 Regulatory Basis and Scope of Application
The compliance certificate is based on the "Export Control List of Dual use Items of the People's Republic of China" (Announcement No. 51 of 2024)
and the "Catalogue for the Administration of Import and Export Licenses for Dual use Items and Technologies". Laser engraving machines mainly
involve clause 6A205 in category 6 "sensors and lasers", and some high-precision equipment may also involve clause 2B201 in category 2 "material
processing equipment". Customs supervision implements the principle of "parameter to standard", which determines whether an item falls within
the scope of control based on objective technical indicators, rather than solely relying on the declared purpose of the enterprise.
2、 The technical red line for regulated lasers
According to clause 6A205, if the laser equipped on the laser engraving machine belongs to the following types and reaches the corresponding
parameter threshold, it falls within the regulatory range:
Copper vapor laser: operating wavelength of 500-600nm, average output power ≥ 30W.
Argon ion laser: operating wavelength of 400-515nm, average output power ≥ 40W.
Neodymium doped laser (non glass laser): Output wavelength 1000-1100nm, using pulse excitation and Q-switch, pulse width ≥ 1ns, and single
transverse mode average output power exceeding 40W or multiple transverse modes exceeding 50W; or frequency doubled output wavelength
500-550nm, average power exceeding 40W.
Adjustable pulse dye laser: operating wavelength of 300-800nm, average output power exceeding 1W (single-mode oscillator) or 30W (amplifier/
oscillator), repetition rate exceeding 1kHz, pulse width less than 100ns.
Pulsed carbon dioxide laser: wavelength 9000-11000nm, repetition rate exceeding 250Hz, average power exceeding 500W, pulse width less than 200ns.
Pulse carbon monoxide laser: wavelength 5000-6000nm, repetition rate exceeding 250Hz, average power exceeding 200W, pulse width less than 200ns.
3、 Key detection parameters and testing methods
Compliance certification requires precise measurement of the following core parameters:
Output wavelength: Use a spectrometer to measure the operating wavelength range of the laser and determine whether it falls within the controlled
wavelength range.
Average output power: Use a laser power meter to measure the average output power under stable working conditions, distinguishing between
continuous wave and pulse modes.
Pulse width: Use a high-speed photodetector in conjunction with an oscilloscope to measure the pulse duration and determine if it is less than the
control threshold (such as 200ns).
Repetition rate (pulse frequency): measures the number of pulse emissions per unit time to determine if it exceeds threshold values such as 250Hz
or 1kHz.
Transverse mode: The output is determined by the beam quality analyzer to be a single transverse mode (TEM ₀₀) or multiple transverse modes,
corresponding to different power threshold standards.
Beam divergence angle and energy stability: For special types such as target indicating lasers, it is necessary to check whether the beam divergence
angle is less than 0.3mrad and whether the energy stability is better than 15%.
4、 Explanation of exemption situation
The compliance certificate should clearly state whether the following exemption conditions exist:
Continuous wave or long pulse exemption: Continuous wave CO ₂ lasers (usually 1-5kW) used for industrial cutting and welding, as well as pulse lasers
with a pulse width exceeding 200ns, are clearly not subject to the regulations of 6A205. g and 6A205. j.
Exemption for single-mode oscillators: If the average output power of an adjustable pulse single-mode dye laser oscillator exceeds only 1W, it belongs
to a clearly unregulated range.
Usage does not change attributes: Even if the laser engraving machine is declared for civilian use (such as advertising processing, handicraft engraving),
as long as the technical indicators reach the regulatory threshold, a license still needs to be applied for; On the contrary, if the technical indicators are
below the threshold, even if it has the ability to carve metal, it is not a controlled item.
5、 Compliance Conclusion and Statement
The compliance conclusion should clearly state one of the following judgments:
Belonging to controlled items: List the specific applicable control codes (such as 6A205. a, 6A205. c, etc.), and suggest that enterprises apply to the Ministry
of Commerce for the "Dual Use Items and Technology Export License".
Not classified as a controlled item: Detailed list of measured parameters and comparative analysis with the control threshold, and issue a "Declaration of
Non dual-use Item Control Scope".
Parameter approaching control standards: Even if it does not fall into the list, if the parameter approaches the threshold, it should be noted in the remarks
column of the customs declaration form as "not belonging to export control items" and specific parameters should be filled in for submission in case of
customs questioning.
6、 Qualification requirements for testing institutions
The institution issuing the compliance certificate must have CNAS (China National Accreditation Service for Conformity Assessment) or CAL (China
Assessment and Testing Laboratory) qualifications. Customs has the right to require enterprises to provide test reports issued by laboratories with
internationally recognized qualifications when they are unable to determine the attributes of items. The report should include environmental conditions
for testing, traceability information of instruments and equipment used, raw data records, and uncertainty analysis to ensure data traceability and
recheckability.
7、 Supporting documents and export declaration requirements
In addition to compliance certification, companies should also prepare:
Product Technical Manual: Detailed listing of all technical parameters such as wavelength, pulse width, power, transverse mode, number of control
axes, positioning accuracy, etc.
End user certificate: issued by overseas clients, specifying the end use and end user information.
Customs declaration form filling standards: For controlled items, the remarks column of the customs declaration form must indicate "dual-use items"
and specify the control code; For items that do not belong to but have similar parameters, it is necessary to indicate "not belonging to dual-use items"
and fill in specific parameter indicators.
8、 Violation risk and legal responsibility
According to Announcement No. 77 of the General Administration of Customs in 2026, starting from June 30, 2026, the export of laser processing
equipment (including laser engraving machines) must be verified throughout the entire process to determine whether it involves dual-use item control.
Violation of export regulations will face a fine of 5 to 10 times the value of the goods if the value of the goods exceeds 500000 yuan; Fines ranging from
500000 to 2.5 million yuan for goods with a value below 500000 yuan; Those with serious circumstances shall be held criminally responsible. The scope
of accountability covers the entire chain of factories, foreign trade companies, freight forwarders, customs brokers, and shippers, and there is no exempt subject.
