Taiwan export controls explained: Strategic High-Tech Commodities (SHTC), the Entity List and export permits

The legal basis

The statute is Article 13 of the Foreign Trade Act: no export of strategic high-tech commodities without authorisation, no change of importer or diversion to a third country without approval, and truthful declarations of end user and end use. The detail lives in the Regulations Governing the Export and Import of Strategic High-tech Commodities, issued under that article.

The authority

The desk is the Ministry of Economic Affairs’ International Trade Administration (ITA) — until 26 September 2023 the Bureau of Foreign Trade, a name older guidance still uses. ITA maintains the SHTC portal, the lists and the online screening tools, with classification support available through ITRI.

Five lists and a catch-all

Taiwan controls through five lists: a dual-use list and a Common Military List in the familiar Wassenaar-derived format, plus destination lists for Russia and Belarus, North Korea, and Iran. A catch-all sits underneath: items on no list become SHTC where weapons-of-mass-destruction end use is suspected. Worth saying plainly, because coverage abroad suggests otherwise: of the ten-thousand-plus controlled items, only a narrow band of wafer-fabrication equipment categories is restricted specifically towards mainland China. Thylon classifies against the Taiwanese lists in the same pass as the US and EU ones.

The Entity List: eleven thousand names and counting

Taiwan’s sharpest instrument is the SHTC Entity List: exporting any goods — listed or not — to a listed entity requires a prior SHTC permit, and customs holds unlicensed shipments at the border. The list has been growing in sprints. On 10 June 2025 ITA added 601 entries, bringing the list to 10,844 by its own count — the update that put Huawei, SMIC and their subsidiaries on it. Further rounds followed in September and December 2025 and through 2026; after the 22 October 2026 update ITA puts the list at more than 11,660 entries spanning Russia, Iran, mainland China, Myanmar and beyond.

A list that moves this fast makes one-time screening a fiction. Thylon’s screening module carries the Taiwan MOEA list beside the EU, UN, US and UK stacks and re-screens open transactions as updates land.

Permit types

The workhorse is the individual export permit under Article 15 of the SHTC Regulations: valid six months, split shipments allowed, and valid two years for destinations belonging to all four multilateral regimes. Small shipments to the US and Japan below NT$300,000 FOB can move on an exemption after an Entity List check, and exporters with a certified Internal Compliance Programme can hold a three-year multi-destination permit under Article 15-1 — against an annual internal audit filed by 31 March.

Applications ride on end-use evidence: an International Import Certificate or government assurance from the importing country, or a written end-use assurance from the importer or end user. Records keep for five years. Thylon drafts the permit applications and the assurance paperwork in one motion.

Why a Taiwan permit does not replace an EAR licence

The lists rhyme without matching. Analysts tracking the overlap put well over a thousand entities on both the Taiwanese and the US Entity Lists, and the alignment has tightened sharply since 2022 — but each list still carries names the other lacks. A counterparty absent from Taiwan’s list can still be on the US one, and a shipment with US-origin content answers to the EAR regardless of what Taipei requires. Clearing one regime clears one regime; the triple exposure is the normal case, not the edge case.

What changed in 2025–2026

• 10 Jun 2025 — ITA added 601 entries to the SHTC Entity List — including Huawei, SMIC and subsidiaries — bringing it to 10,844 by ITA's count.
• 16 Sep 2025 — A further 279 entries were added and 7 removed.
• 19 Dec 2025 — 213 entries were added, taking the list past 11,200.
• 2026 — Updates continued on 1 April (67 added), 9 June (265 added, 13 removed) and 22 October (343 added, 90 removed), leaving the list at more than 11,660 entries by ITA's count.

Primary sources

• ITA — Strategic High-Tech Commodities portal
• Laws & Regulations Database — SHTC Regulations (English)
• ITA — Entity List update of 10 June 2025
• ITA — Entity List update of 9 June 2026
• ITA — screening tools and list downloads

Where this fits

Export control rarely means one regime at a time. The pages below cover the rest of the map, and the product pages show how Thylon turns each list and licence type into drafted, cited work your officer signs off.