items specifically designed to measure, test, evaluate and examine items 1) to 7) above.
Our Key Observations
1. Regulatory changes affecting importers and exporters
Prior to the advent of the Export Control Law and the Encryption Announcement, the import and export of encryption items in China were administered by the SCA. Specifically, importers and exporters of encryption items were required to apply with the SCA or its local (provincial, regional or municipal) counterparts for the “Encryption Products and Equipment Containing Cryptographic Technology Import License” or the “Commercial Encryption Product Export License.”
After January 1, 2021, the import and export of commercial encryption items will be governed by the Encryption Announcement as well as the applicable laws, in particular the Encryption Law, the Export Control Law and the Customs Law. MOFCOM will become the central authority (though it may consult with SCA and/or GAC) to review and issue the “Import L