Starting from 2026, Thailand will officially implement new export licensing regulations for Dual-Use Items (DUI), based on the TCWMD Act to align with UN Security Council Resolution 1540 and strengthen compliance control over related trade.
The new rules, led by Thailand’s Department of Foreign Trade (DFT), will be rolled out in phases: the e-DUI application portal will go live in December 2025, the pilot program for Category 0 of the EU Dual-Use List (nuclear and heavy equipment) will launch in Q1 2026, expansion to Categories 7-9 will follow within the year, and full coverage of all categories will be achieved eventually.
For licensing application and management, the regulations specify the principle of "one item, one license; one country, one customer" for annual licenses, with a 90-day validity period. A single transferee can cover up to 5 items, the review cycle will not exceed 45 days, and a re-export report must be submitted within 30 days after export. Enterprises with an established Internal Compliance Program (ICP) can apply for an Inclusive License to streamline high-frequency transactions. If a product falls under the HS code list but its technical parameters do not meet control standards, it can be declared exempt with the "EXEMP" code. Meanwhile, customs and DFT are authorized to detain or temporarily seize suspicious non-compliant goods.
All Thai export entities (including foreign-funded enterprises) must comply with the new regulations, which cover export, re-export, transit, and specific intermediary activities. Violators will face both criminal and administrative penalties. Enterprises in nuclear industry, heavy machinery, precision instruments, and specialty chemicals will be most directly affected. SMEs without an ICP may see an increase in compliance costs.
Cross-border sellers and export enterprises need to take action during the window period: before Q1 2026, conduct self-assessment of product HS codes and technical parameters against the list, register an e-TCWMD system account, and establish a compliance team and approval process. After the implementation of the new rules, strictly follow the licensing application and reporting deadlines, and retain full-chain transaction records. In the long term, it is necessary to establish a regular compliance audit mechanism to dynamically adapt to the pace of category expansion.
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