No. Under U.S. law, the Hong Kong Special Administrative Region (HKSAR) and China (or Mainland China) continue to be treated as two separate destinations for export control purposes. (See Country Chart in part 738 of the Export Administration Regulations (EAR)(Supplement No. 1 to 15 CFR 738)).
Certain items subject to the EAR that do not require a Commerce Department license for export from the United States to Hong Kong will require a license for reexport from Hong Kong to China. To determine if your reexport requires a license to China, determine whether the export of the item from the United States to China would require a license.
There are certain limited circumstances in which a license exception may also be available for reexport to China, based on a number of factors, including the Export Commodity Classification Number (ECCN), the end-user and the end-use. You should consult part 740 of the Export Administration Regulations (15 CFR 740) for details on whether or not a license exception is available for reexport to China.
There are certain limited circumstances in which a license exception may also be available for reexport to China, based on a number of factors including the Export Commodity Classification Number (ECCN), the end-user and the end-use. You should consult part 740 (15 CFR 740) of the Export Administration Regulations for details on whether or not a license exception is available for reexport to China.
In most cases a license issued for an export to Hong Kong is valid only for export to Hong Kong. If your item(s) is destined for end-use in China, then a reexport license for China must be obtained from the Department of Commerce for the export to China. However, if prior to export from the U.S. you know that the item will be reexported to China, you can apply for a license for both export to Hong Kong and reexport to China. In addition, there are certain limited circumstances under which a license exception may be available for reexport to China. See part 740 of the EAR (15 CFR 740) for details on available license exceptions.