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Policy & Geopolitics · · 5 min read

China's mineral export controls since 2023, in the order they came

A dated sequence of China's export-control announcements on minerals from July 2023: what each one added, when it took effect, and which were later suspended and until when.

Reviewed by Peter Uppal

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The short version

Since July 2023, China's Ministry of Commerce (MOFCOM), mostly jointly with the General Administration of Customs, has placed a series of minerals and related items under export licensing: gallium and germanium, graphite, antimony, tungsten and four other metals, seven elements it groups as medium and heavy rare earths, and in October 2025 a wider package. A one-year suspension issued on 7 November 2025 paused the October 2025 package until 10 November 2026, and a separate notice paused the US-specific restrictions on several of these materials until 27 November 2026. The item-control notices' own operative words are, in this publication's translation, "may not be exported without a licence"(opens in a new tab), which is a licensing requirement rather than a ban.

2023: gallium, germanium and graphite

MOFCOM and Customs Announcement No. 23 of 2023, issued on 3 July 2023, placed gallium- and germanium-related items under export control from 1 August 2023(opens in a new tab). The notice's own words, in this publication's translation, are that items with the listed characteristics "may not be exported without a licence"(opens in a new tab).

Graphite followed in Announcement No. 39 of 2023, published on 20 October 2023 and effective from 1 December 2023(opens in a new tab). It covers high-purity, high-strength, high-density artificial graphite materials and their products, and natural flake graphite and its products(opens in a new tab), under the same licence wording; for the artificial graphite, the thresholds are purity above 99.9%, flexural strength above 30 MPa and density above 1.73 g/cm³(opens in a new tab).

In December 2023, Reuters reports, Beijing banned the export of technology to make rare earth magnets(opens in a new tab).

2024: antimony, and one country singled out

Announcement No. 33 of 2024, issued on 15 August 2024 and effective from 15 September 2024, placed antimony-related items, including antimony ores and raw materials and antimony metal and products, under export licensing(opens in a new tab). It also covered superhard materials, which in the IEA's summary include six-sided top press equipment and synthetic diamond technology(opens in a new tab).

MOFCOM Announcement No. 46 of 2024, issued by MOFCOM alone on 3 December 2024, took effect on publication and was aimed at one destination(opens in a new tab). It prohibited the export of dual-use items to US military users or for military uses(opens in a new tab). For gallium, germanium, antimony and superhard materials going to the United States, the notice says, in this publication's translation, that "licences will in principle not be granted"(opens in a new tab), which Pillsbury's table records as prohibited in principle (presumed denial)(opens in a new tab) and USGS's 2026 edition describes as a ban(opens in a new tab). Graphite exports to the United States were made subject to stricter end-user and end-use review(opens in a new tab).

2025: five metals, seven rare earths, then a package

In February 2025, USGS records, China implemented export controls and licensing requirements on bismuth, indium, molybdenum, tellurium and tungsten(opens in a new tab), under MOFCOM and Customs Announcement No. 10 of 2025, issued on 4 February 2025 and effective on publication(opens in a new tab).

Announcement No. 18 of 2025, issued on 4 April 2025, came into effect on the date of issuance(opens in a new tab) and placed under licence seven elements the announcement groups as medium and heavy rare earths: samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium, with exporters to apply for a licence(opens in a new tab). USGS records the April controls on the same seven elements(opens in a new tab).

"To export the above-described items, the exporter shall apply for the license from the competent commercial authority of the State Council." MOFCOM and Customs, Announcement No. 18 of 2025 (English reference text)

On 9 October 2025 MOFCOM issued six announcements together. Four were joint with Customs: No. 55 on superhard materials(opens in a new tab), No. 56 on certain rare-earth equipment and raw and auxiliary materials(opens in a new tab), No. 57 on five further rare earths, holmium, erbium, thulium, europium and ytterbium(opens in a new tab), and No. 58 on lithium batteries and artificial-graphite anode materials(opens in a new tab). Nos. 61 and 62 were MOFCOM's alone. No. 61 concerns, in this publication's translation of its title, "relevant rare-earth items abroad"(opens in a new tab), which CIRS describes as extending controls to foreign-made products containing a certain proportion of Chinese-origin rare earths(opens in a new tab). No. 62 places rare-earth technologies under licence(opens in a new tab). The notices set different start dates: Nos. 55 to 58 were to take effect on 8 November 2025 (55(opens in a new tab), 56(opens in a new tab), 57(opens in a new tab), 58(opens in a new tab)); No. 61 had parts effective on publication and parts from 1 December 2025(opens in a new tab); No. 62 took effect on issuance(opens in a new tab).

The suspensions

On 7 November 2025 MOFCOM and Customs issued Announcement No. 70 of 2025, suspending Nos. 55 to 58, 61 and 62 until 10 November 2026(opens in a new tab). The notice's word, in this publication's translation, is "suspended"(opens in a new tab), and the suspension also covered the parts of Nos. 61 and 62 already in force. USGS's 2026 edition records that in late October, following an agreement with the United States Government, China suspended the October controls for 1 year(opens in a new tab) and left the April controls in effect(opens in a new tab); No. 70 does not list No. 18.

On 9 November 2025, MOFCOM Announcement No. 72 suspended, until 27 November 2026, paragraph 2 of No. 46(opens in a new tab), the paragraph covering gallium, germanium, antimony, superhard materials and graphite exports to the United States(opens in a new tab). The prohibition on dual-use exports to US military users, in paragraph 1 of No. 46, was not among the suspended provisions(opens in a new tab).

2026: enforcement in the notices read

MOFCOM Announcement No. 26 of 2026, issued on 24 June 2026 and effective from 1 July 2026, set out how reports of violations of export controls on strategic-mineral dual-use items are handled(opens in a new tab). It adds no item controls(opens in a new tab). In June 2026 China also added 10 US entities, including MP Materials and USA Rare Earth, to its export control list(opens in a new tab).

Related

  • Export Controls
  • Critical Mineral Strategies
  • National Security
  • Supply Chain Risk
  • Global Trade

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