Developments

Export controls, trade policy, and regulatory changes affecting strategic material supply chains

12 articles
Analysis
In Force

China's invisible rare earth wall: why suspended controls don't mean available supply

Analysis of the six-layer domestic regulatory architecture — production quotas, SOE duopoly, mandatory traceability, customs enforcement, VAT structure, and regulatory ambiguity — that constrains rare earth trade regardless of whether MOFCOM export controls are formally active. Heavy REE mining quotas frozen at 19,150 t for six years; 80.7% of historical thulium supply was illegally produced; customs enforcement cases up 248% in 2025.

SmGdTbDyLuScYHoTmEuErYb
[1] State Council Order No. 785, Rare Earth Management Regulations — 稀土管理条例, effective 1 Oct 2024 — 32-article framework, never suspended [2] Zhang et al., Journal of Industrial Ecology, 2024 — 80.7% of China's Tm production 2011–2020 from illegal mining (1,506 t cumulative) [3] MOFCOM/GAC enforcement data, 2025 — Administrative cases: 91 (2024) → 317 (2025), +248%; max fine RMB 6.34M
Timeline
Sanctions
In Force

China sanctions 15 Japanese defence entities

MOFCOM designates 15 Japanese companies as "unreliable entities," prohibiting export of controlled items (including all dual-use minerals). Retaliatory measure following Japan's Jan 2026 prohibition order targeting Chinese semiconductor firms.

MOFCOM Announcement No. 17 of 2026
Export Ban
In Force

Japan prohibited from receiving Chinese dual-use exports

China prohibits export of dual-use items to Japan, citing Japan's restrictions on semiconductor equipment to China. Covers gallium, germanium, antimony, rare earths, and all items on China's dual-use export control...

GaGeSbWTeBi +9
MOFCOM Announcement No. 1 of 2026
Suspension
In Force

China suspends Oct 2025 escalation measures until Nov 2026

Following diplomatic engagement, MOFCOM suspends all six October 2025 announcements (Nos. 55–58, 61, 62) plus the Ga/Ge/Sb US-specific ban (Art. 2, No. 46/2024). Suspension runs until 28 November 2026. Underlying...

GaGeSbWTeBi +9
MOFCOM Announcements No. 70 and No. 72 of 2025
Escalation
Suspended

China escalates: six announcements tighten controls and ban US exports

Six simultaneous announcements (Nos. 55–58, 61, 62) dramatically tighten enforcement: suspend all pending licence applications, halt new applications for US-destined shipments, add end-user verification requirements, and expand controlled item scope....

GaGeSbWTeBi +9
MOFCOM Announcements No. 55, 56, 57, 58, 61, and 62 of 2025
Export Control
In Force

China imposes export controls on seven medium and heavy rare earths

Export licences required for samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium — covering metals, alloys, oxides, compounds, and permanent magnet materials. Announced in direct retaliation to escalating US tariffs....

SmGdTbDyLuSc +1
MOFCOM/GAC Announcement No. 18 of 2025
Export Control
In Force

China extends export controls to tungsten, tellurium, bismuth, molybdenum, and indium

All five metals now require export licences. Controls took effect immediately upon publication, citing national security and non-proliferation. Tellurium controls are notable as Te is critical for CdTe thin-film solar...

WTeBiMoIn
MOFCOM/GAC Announcement No. 10 of 2025
Export Ban
In Force

China bans gallium, germanium, and antimony exports to the United States

Article 1 of Announcement No. 46/2024 prohibits export of Ga, Ge, and Sb (and their compounds) to any US military end-user or military end-use. Article 2 imposes a blanket ban...

GaGeSb
MOFCOM Announcement No. 46 of 2024
Regulation
In Force

Rare Earth Management Regulations enter into force

State Council Order No. 785 establishes comprehensive regulatory framework for rare earth mining, smelting, separation, and circulation. Codifies production quotas, traceability requirements, and strategic reserve management. Provides the legal infrastructure...

State Council Order No. 785, 'Rare Earth Management Regulations'
Export Control
In Force

China restricts antimony exports

Export controls imposed on antimony and related items, effective 15 September 2024. Antimony is critical for flame retardants, lead-acid batteries, ammunition, and infrared optics. China produces ~48% of global antimony;...

Sb
MOFCOM/GAC Announcement No. 33 of 2024
Regulation
In Force

EU Critical Raw Materials Act enters into force

Regulation (EU) 2024/1252 establishes benchmarks for domestic extraction, processing, and recycling of critical raw materials including rare earths, gallium, and germanium. Sets targets of 10% extraction, 40% processing, and 25%...

Regulation (EU) 2024/1252
Export Control
In Force

China imposes first export controls on gallium and germanium

China announced export licence requirements for gallium and germanium products, effective 1 August 2023. These were the first targeted critical mineral export controls, widely interpreted as a response to US...

GaGe
MOFCOM/GAC Announcement No. 23 of 2023