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On 31 December 2013, the State Encryption Management Bureau (SEMB) issued Announcement No. 27 and adjusted the Catalogue for the Administration of Import of Encryption Products and Equipment Containing Encryption Technology (the Adjusted Catalogue), replacing the Catalogue for the Administration of Import of Encryption Products and Equipment Containing Encryption Technology (First Batch) annexed to SEMB Notice No. 18 and effective on January 1, 2010 (the Original Catalogue). The new Catalogue was effective from January 1, 2014.
The Adjusted Catalogue now clearly excludes: (a) smart cards for digital TV, (b) Bluetooth modules, and (c) dongles used for intellectual property protection purposes from the scope of commercial encryption products which are subject to an Import Permit requirement. Prior to this adjustment, there have been quite a few cases where SEMB and / or Customs queried importers of security tokens with encryption and detained some shipments at several ports of entry in China. Password cards no longer subject to the Import Permit requirement under the Adjusted Catalogue, may also no longer be subject to other encryption controls such as use, export, development, production and sale of commercial encryption products in China. For a list of products covered by the Adjusted Catalogue, please see the Client Alert: Adjustment to the Catalogue for the Administration of Import of Encryption Products and Equipment Containing Encryption Technology prepared by our Hong Kong office. If you have any questions on this subject, please contact William Marshall or Anne Peng of the Hong Kong office or Jon Eichelberger of the Beijing office. |
