From July 30, 2026, exporters of certain dual-use items (DUI) will require export licenses before goods can be cleared for export. Importantly, license verification is now integrated into Thailand's customs clearance process, meaning non-compliance can result in shipments delays, export holds, and potential enforcement actions.

What Is Changing? 

Thailand’s National Control List, issued in May 2026, retains the two-schedule structure adopted in the 2021 regulations:

Schedule One – Controlled Dual-Use Items [1]

• Covers controlled dual-use items under Categories 0–9.
• Largely based on the EU’s 2023 Dual-Use Control List. 
• Licenses are required when the relevant technical parameters are met.

Schedule Two – Watch List [2]

• Identifies specific HS codes subject to enhanced scrutiny from an end-use and end-user perspective. 
• Unlike broader catch-all controls in other jurisdictions, Thailand’s Schedule Two applies only to the products expressly identified in the list.
• No separate licensing or reporting obligations currently apply.

The initial rollout targets Category 0 items, covering nuclear materials, facilities, and equipment. Effective July 30, 2026, licenses will be required for [3]:

• 0A – Systems, Equipment, and Components
• 0B – Test, Inspection, and Production Equipment
• 0C – Materials

The Department of Foreign Trade (DFT) has indicated that additional categories may be introduced in the near future, possibly by the end of this year or early next year. Businesses should continue monitoring these developments, especially those operating in aerospace, aviation, marine technologies, advanced manufacturing, and related sectors.
 

What Exporters Must Now Do

Thailand’s DFT has introduced the electronic Trade Controls on WMD (e‑TCWMD) platform, which integrates classification, licensing, and reporting into a single workflow [4]. Exporters must perform self-classification using this system, drawing on both tariff classification (HS codes) and technical inputs. 

Products outside the scope of control may proceed without restriction, while products meeting the relevant technical criteria require a license. Where an item falls within the relevant HS code range but does not satisfy the control criteria, exporters must retain documentation supporting that conclusion.

Although the current framework is largely transaction-based, Thailand has introduced a voluntary Internal Compliance Program (ICP) certification framework administered by the DFT [5]. The ICP provides a structured approach to export control compliance and may support future facilitation measures.

Another key component of the licensing process is the end-use statement completed by the end-user [6]. The statement confirms that the item will not be used in connection with weapons of mass destruction (WMD) activities and will not be re-exported contrary to regulatory requirements. As a result, exporters may need to engage more closely with customers and counterparties to obtain sufficient end-use information before exports proceed. This introduces new coordination challenges, which may not always be readily available or standardized.

The ‘Locked’ Customs Workflow

One of the most significant aspects of the regime is the integration of licensing requirements into customs procedures. Once a license is approved, exporters must submit a pre-shipment notification through the DFT system, linking the license to the relevant invoice details. The DFT then transmits the information to the National Single Window (NSW) system and issues a reference number, which must be declared in the customs export system before the shipment can be cleared for export. 

The Customs Department has operationalized this linkage through the NSW and the export declaration process [7]. In-scope HS codes are flagged in the customs system, requiring the relevant license, exemption, or reference number before export clearance.

This creates a ‘locked’ workflow in which customs clearance is contingent on compliance. Without a valid license or exemption reference, shipments cannot proceed. Compliance is therefore a prerequisite for export clearance. Delays in classification, documentation, or licensing can directly affect shipment timelines. 

Non-compliance may lead not only to shipment delays but also to regulatory fines and penalties under the TCWMD Act and/or related customs laws. Accordingly, businesses should ensure that appropriate compliance controls and governance mechanisms are in place to mitigate shipment delays and enforcement risks.

Conclusion

With the first licensing phase going live on July 30 for Category 0, the window to prepare is short. The phased implementation approach provides some time for preparation but also signals that the scope of the regime will expand significantly over the near term. 

Exporters should therefore begin identifying potentially affected products, establish classification procedures, and develop processes for obtaining and retaining end-use information. Companies with recurring exports of potentially controlled items may also consider implementing an ICP to strengthen compliance governance and position themselves for potential future licensing facilitation as Thailand’s export control regime evolves.

How A&M Can Help

A&M’s Global Trade team assists companies in translating regulatory requirements into practical compliance programs. Our export control services include:

Readiness Assessments

• Identify potential licensing risks and compliance gaps.
• Evaluate readiness against current and future DFT requirements.

Classification and Licensing Support

• Product classification reviews.
• License application support and end-use documentation reviews.

ICP Design and Compliance Governance

• Internal Compliance Program design.
• Management and employee training.

Customs and Operational Readiness

• Customs process and workflow reviews.
• Integration of licensing requirements into export operations.

Ongoing Regulatory Monitoring

• Monitor future rollout phases and regulatory developments.

• Assess business impacts and emerging compliance obligations.

  ---

References

[1] Notification of the Ministry of Commerce on List of Goods Related to the Proliferation of Weapons of Mass Destruction, B.E. 2569 (2026)

[2] Notification of the Ministry of Commerce on List of Goods Related to the Proliferation of Weapons of Mass Destruction, B.E. 2569 (2026) 

[3] Notification of the Ministry of Commerce on Designating Dual-Use Items as Goods Requiring Authorization for Export and Re-Export Out of the Kingdom, B.E. 2569 (2026)

[4] Department of Foreign Trade, Ministry of Commerce (Thailand), Information Technology System to Support Thailand's Dual‑Use Goods Trade Management System (e‑TCWMD).

[5] Notification of the Department of Foreign Trade on Rules for the Certification of Internal Trade Compliance Systems for Goods Related to the Proliferation of Weapons of Mass Destruction, B.E. 2564 (2021) 

[6] Notification of the Ministry of Commerce on Rules, Procedures, and Conditions for Permitting the Export and Re-export of Dual-Use Items Out of the Kingdom, B.E. 2569 (2026)

[7] Customs Notification No. 85/2569 on the Electronic Integration of Licenses and Certificates with the Department of Foreign Trade, Item no. 7, Effective July 30, 2026