Recently, Kunming Customs issued a notice of information on customs administrative penalty cases (Mengla Guan Ji Violation Word [2025] 137), saying that Zhejiang Hongshi Building Material Technology Co., Ltd. was fined RMB 222000 yuan for false declaration of export goods tariff numbers and unauthorized export of controlled items. On January 9 and February 14,
2025, Zhejiang Hongshi Building Material Technology Co., Ltd. entrusted Xishuangbanna Ningbo Freight Forwarding Co., Ltd. to declare two tickets of goods for export to Mengla Customs in the form of general trade. Among them, the goods declared on January 9 are cement grinding AIDS, the commodity code is 3824409000, the quantity is 29.63 tons, and the total declared price is RMB 254136; The goods declared on February 14 are the mixture of diethanol monoisopropanolamine, the commodity code is 3824999999, the quantity is 29.41 tons, and the total declared price is RMB 0.02 256514.
After investigation, it was found that the specifications and models of the above two tickets contained "triethanolamine 20%". According to the Notice of the Ministry of Industry and Information Technology, the Ministry of Commerce and the General Administration of Customs on Optimizing the Import and Export Supervision Measures of Low Concentration Triethanolamine Mixtures (2024 Edition) (MIIT Lian Wei Han [2024] No.377), such goods are subject to the Import and Export Approval Form of Controlled Chemicals and the Import and Export License of Dual-use Items and Technologies. However, Zhejiang Hongshi Building Material Technology Co., Ltd. did not provide regulatory documents as required because it was not familiar with the relevant export control regulations, which constituted an act of exporting controlled items without permission.
Legal basis and punishment decision
As a domestic consignor, the party concerned violated the provisions of Article 19, paragraph 1, of the Export Control Law of the People's Republic of China, Article 10, paragraph 3, and Article 24, paragraph 1, of the Customs Law of the People's Republic of China. It constitutes an illegal act stipulated in Article 12 of the Regulations of the People's Republic of China on the Implementation of Customs Administrative Penalties. In view of the fact that the party concerned voluntarily confessed the illegal acts that the Customs had not yet grasped, which conformed to the circumstances of mitigating punishment, Kunming Customs finally made an administrative penalty decision of RMB 22,200 in accordance with the first paragraph of Article 34 of the Export Control Law of the People's Republic of China and the relevant provisions of the Administrative Punishment Law of the People's Republic of China.
This case once again reminds import and export enterprises that they must strictly abide by national export control laws and regulations, accurately declare cargo information, and timely handle relevant regulatory documents. Especially when it comes to sensitive goods such as chemicals, enterprises need to strengthen internal compliance training to avoid administrative penalties caused by negligence. Customs will continue to strengthen supervision, safeguard national security and trade order, and provide legal protection for Yunnan's high-level opening to the outside world.
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