# China curbs tunnel boring machine exports under dual-use law

*MOFCOM Announcement No. 50 requires export permits for shield tunneling units and cutterheads starting Nov. 18, exposing international rail and subway contractors to supply bottlenecks.*

**Published:** October 19, 2026  
**By:** Hao Feng  
**Section:** Trade & Industrial Policy — China  
**Format:** Policy Tracker  
**Confidence:** high  
**Source:** https://eastasiabrief.com/trade-policy/china-curbs-tunnel-boring-machine-exports-under-dual-use-801  
**Publisher:** East Asia Brief (https://eastasiabrief.com/)

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## What to know

- MOFCOM mandates dual-use export permits for tunnel boring machines starting Nov. 18, 2026
- China accounts for roughly 70% of global shield machine production and exports over 600 units annually
- CRCHI books about 14% of its 10.1 billion yuan revenue from overseas sales now subject to licensing

![Workers assemble and weld massive tunnel boring machine cutterheads inside an industrial manufacturing facility. (AI-generated image)](https://eastasiabrief.com/media/2026-10-19-e5cb991eb0f1.webp)
*Workers assemble and weld massive tunnel boring machine cutterheads inside an industrial manufacturing facility. (AI-generated image)*

China's Ministry of Commerce restricted exports of tunnel boring machines on Oct. 19, 2026, requiring dual-use government licenses for heavy excavators that account for roughly 70% of global production.

The ministry issued Announcement No. 50 alongside the General Administration of Customs, citing national security and dual-use control rules. Chinese builders supply more than 600 shield machines annually to international transit projects.

China exported $1.2 billion in tunneling equipment last year, according to customs records. The new controls cover full-face earth pressure balance shields and slurry machines valued up to $25 million per unit.

The measure covers full-face tunnel boring machines under export control code 2B906. Controlled systems include earth pressure balance machines, slurry shields, open-type units, and rock shields classified under customs tariff code 8430313010.

Earth pressure balance machines use excavated soil under pressure to support tunneling faces in soft ground. Slurry shields circulate pressurized fluid to stabilize saturated soil during deep underwater or metro excavations.

Under separate control code 2A906, Beijing placed export restrictions on specially designed tunneling assemblies. The list targets cutterheads and rolling cutters under tariff code 8431499910 and main drive transmission units.

The component restrictions also cover screw conveyors under tariff code 8428310010 and hydraulic segment erectors under code 8479899959. Exporters must also obtain ministry authorization to ship remanufacturing engineering technology used for refurbished machinery.

China Railway Construction Heavy Industry Corporation makes roughly a third of all Chinese-built shield tunneling units. Overseas machine deliveries generated about 14% of the manufacturer's 10.1 billion yuan ($1.42 billion) in revenue last year.

The company exports specialized tunneling equipment to contractors across 35 countries. Its overseas backlog includes metro boring shields earmarked for municipal subway extensions in Southeast Asia and Eastern Europe.

China Railway Engineering Equipment Group, a subsidiary of state-owned China Railway Group, operates 18 production bases across China. The equipment unit has built over 1,500 tunneling machines for domestic and foreign transit systems.

International sales generated roughly 11% of the group's tunneling machinery division revenue during the prior fiscal year. The unit recently supplied super-large slurry shields exceeding 15 meters in diameter for undersea roadway projects.

Overseas infrastructure builders face immediate procurement risks in heavy rail and metro construction. Contractors in India rely on Chinese manufacturers for approximately 60% of their active urban tunnel boring machinery.

Indian municipal metro authorities in Delhi, Mumbai and Bengaluru run multiple underground extension corridors using imported Chinese rigs. Project operators face prospective delivery delays of four to eight months if export clearances stall.

Contractors in Singapore and Malaysia also depend on Chinese tunnel boring machines for cross-island rail links. Specialized underground machines require custom fabrication schedules that typically run between 10 and 14 months per unit.

German competitor Herrenknecht AG holds about 20% of the international market for large-diameter shield machines. The company maintains manufacturing plants in Germany and China, supplying European and Asian transit developers.

Herrenknecht could capture diverted international orders if Chinese export licensing slows foreign deliveries. Factory lead times at its German production facilities currently stretch beyond 14 months on specialized rock shields.

Japan's Kawasaki Heavy Industries produces large slurry and shield machines through its machinery division. The company manufactures roughly eight to 10 heavy tunneling units each year, primarily serving Japanese and regional transit clients.

Komatsu and Kanadevia Corporation, formerly named Hitachi Zosen, supply specialized rock and slurry excavators from Japanese factories. Those two builders supply roughly 15% of the Asia-Pacific market for non-Chinese tunneling machinery orders.

Dual-use regulations apply to machinery with civil infrastructure capabilities that could support military underground engineering. Security planners categorize deep-trenching shields as dual-use because identical boring technology excavates hardened military bunkers and subterranean storage.

The tunneling machine decree widens Beijing's dual-use trade controls beyond raw materials and processed minerals. Over the past two years, commerce authorities restricted foreign shipments of gallium, germanium, antimony and synthetic graphite.

Under China's Export Control Law, equipment exporters must submit end-user verification certificates and detailed project documentation. The commerce ministry reviews technical specifications and construction site coordinates before issuing shipment permits.

Exporters that ship controlled tunneling hardware without ministry licenses face administrative fines up to 10 times the illegal transaction value. Customs officials hold authority to confiscate unauthorized shipments at departure ports.

The licensing requirements take effect on Nov. 18, 2026, the ministry said. Exporters must file dual-use applications through provincial commerce bureaus before central authorities issue formal export permits.

The notice does not state whether contracts signed before Nov. 18 will receive grandfathered exemptions, and the ministry has not published standard processing timelines for individual license reviews.

Chinese ports continue to process scheduled equipment shipments under standard customs declarations until the Nov. 18 licensing enforcement date arrives.

## Impact map

| Event | Korea | China | Japan | Global impact |
| --- | --- | --- | --- | --- |
| TBM export licence mandate | Hyundai E&C and Samsung C&T face delivery reviews on overseas metro tunneling jobs | CRCHI and CREG must secure ministerial permits for all foreign equipment shipments | Kawasaki Heavy Industries and Komatsu face surging inquiries for alternative boring rigs | International transit projects encounter lead-time extensions beyond standard 12-month delivery windows |

## In this story

- **Companies:** China Railway Construction Heavy Industry, China Railway Group
- **Tickers:** 688579.SS, 601390.SS
- **Exposed:** Herrenknecht, Kawasaki Heavy Industries, Komatsu, Kanadevia
- **Policy:** Export Controls
- **Impact:** Supply Chain, Compliance, Order Book

## Primary sources

1. mofcom.gov.cn <http://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_9ce34ccfa6c040d7a4f7622f89133be5.html>
2. devdiscourse.com <https://www.devdiscourse.com/article/international/3994600-china-commerce-ministry-announces-export-controls-for-tunnel-boring-machines>
3. arnoldporter.com <https://www.arnoldporter.com/en/perspectives/advisories/2026/07/china-imposes-export-control-and-government-procurement-restrictions-on-designated-us-companies>
4. databridgemarketresearch.com <https://www.databridgemarketresearch.com/reports/global-tunnel-boring-machine-market>
5. globaltimes.cn <https://www.globaltimes.cn/page/202609/1370596.shtml>

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Cite as: East Asia Brief, "China curbs tunnel boring machine exports under dual-use law," October 19, 2026. https://eastasiabrief.com/trade-policy/china-curbs-tunnel-boring-machine-exports-under-dual-use-801