On October 9, 2025, China’s Ministry of Commerce issued six announcements in a single day — Nos. 55, 56, 57, 58, 61, and 62 of 2025 — in the most sweeping expansion of strategic mineral export controls since the rare earth regime began. Exactly one month later, on November 9, all six were suspended.
The suspension runs until November 28, 2026. What happens after that date is the question every procurement officer sourcing heavy rare earths should be asking now.
What the October escalation did
The six announcements operated in concert to achieve four objectives simultaneously:
1. Five new elements brought under control. Announcement No. 61 added holmium, erbium, thulium, europium, and ytterbium to the export control list for the first time. Prior to October 9, these five elements could be exported from China without a MOFCOM licence. Afterwards, they joined the 12 elements already controlled under Announcements No. 18/2025 (Sm, Gd, Tb, Dy, Lu, Sc, Y), No. 10/2025 (W, Te, Bi, Mo, In), and No. 46/2024 (Ga, Ge, Sb).
2. Pending licence applications suspended. Announcement No. 55 froze all pending export licence applications for gallium, germanium, and antimony — meaning shipments that had already been approved in principle were halted mid-process.
3. New US-destined applications blocked. Announcement No. 56 prohibited new licence applications for gallium, germanium, and antimony destined for the United States, extending the Article 1 military end-use ban to a functional blanket prohibition.
4. Enhanced end-user verification. Announcement No. 58 imposed additional end-user verification requirements for all rare earth exports, and Announcement No. 62 expanded the controlled list to include supply chain intermediates — semi-processed materials and alloy precursors that had previously fallen outside the formal control scope.
The timing was unambiguous. The announcements were issued in direct response to US tariff escalation to 145% on Chinese goods, announced on October 7, 2025. China’s retaliatory sequence — from initial tariff response to export control escalation — took 48 hours.
Why Ho, Er, and Tm matter
Holmium, erbium, and thulium are the three rarest commercially traded lanthanides. They are extracted from ionic clay deposits in southern China as minor co-products of the heavy rare earth separation process, meaning their supply is structurally tied to demand for the dominant heavy rare earths (dysprosium, terbium, gadolinium).
Their applications, while niche, are strategically significant:
| Element | Key applications | Annual production est. |
|---|---|---|
| Holmium (Ho) | Magnetic flux concentrators, nuclear control rods, Ho:YAG lasers | ~70 t |
| Erbium (Er) | Fibre optic amplifiers (EDFA), pink glass colourant, nuclear moderator | ~200 t |
| Thulium (Tm) | Portable X-ray sources, Tm:YAG surgical lasers, neutron activation | ~30 t |
Before October 2025, these three elements were among the few heavy rare earths that could be freely exported from China. The October escalation eliminated that distinction — and the suspension has only temporarily restored it.
The November suspension: what it does and does not do
MOFCOM Announcements No. 70 and No. 72, issued November 7–9, 2025, suspended all six October announcements until November 28, 2026. The practical effects:
What the suspension restores:
- Ho, Er, Tm, Eu, and Yb can again be exported without a MOFCOM licence
- Pending Ga/Ge/Sb licence applications that were frozen can proceed
- The blanket US ban on Ga/Ge/Sb (Article 2, No. 46/2024) is paused
- Enhanced end-user verification requirements are lifted
- Supply chain intermediate controls are paused
What the suspension does not change:
- Announcement No. 18/2025 (Sm, Gd, Tb, Dy, Lu, Sc, Y) remains fully active — these seven elements still require export licences with no interruption
- Announcement No. 10/2025 (W, Te, Bi, Mo, In) remains fully active
- Article 1 of No. 46/2024 (Ga/Ge/Sb US military end-use ban) remains permanently active
- The domestic regulatory apparatus — production quotas, traceability system, customs enforcement — continues to operate
The suspension is a diplomatic pause, not a policy reversal. State media explicitly characterised it as a period during which authorities would “study and refine” the controls — language that signals regulatory development, not abandonment.
November 28, 2026: three scenarios
When the suspension expires, three outcomes are possible:
Scenario 1 — Controls reimposed. The October 2025 announcements reactivate automatically. Ho, Er, Tm, Eu, and Yb once again require MOFCOM export licences. This is the default outcome if no further action is taken — suspension expiry reverts to the pre-suspension state.
Scenario 2 — Suspension extended. MOFCOM issues a new announcement extending the suspension for an additional period. This requires active diplomatic conditions that justify continued pause.
Scenario 3 — Revised controls. MOFCOM replaces the October announcements with a refined regulatory framework that permanently incorporates Ho, Er, Tm, Eu, and Yb into the standard export licensing regime — potentially with different terms, thresholds, or end-use exemptions than the October 2025 versions.
The critical planning assumption for procurement is that Scenario 1 is the default. Extending or revising the controls requires affirmative Chinese government action; reimposition requires nothing.
Procurement implications
For buyers sourcing holmium, erbium, or thulium from China, the current suspension window creates a clear decision framework:
- Immediate needs (Q4 2025 – Q3 2026): Procure now while no licence is required. Chinese suppliers are quoting and shipping. Delivery timelines of 2–4 weeks are achievable for standard purities.
- Inventory planning: Consider building strategic inventory of these elements before November 2026. Once controls reimpose, procurement timelines extend to 4–6 months minimum as MOFCOM licensing becomes required.
- Diversification: Identify non-Chinese supply paths now. Western specialty distributors carry holmium, erbium, and thulium at significant retail premiums, but establishing supplier relationships before a potential supply disruption is materially cheaper than doing so during one.
The October 2025 escalation demonstrated that China can expand its export control scope overnight. The suspension demonstrated that it can retract controls nearly as quickly. Both actions serve the same strategic purpose: maintaining optionality over the global supply of materials for which no adequate non-Chinese substitute exists at scale.
Regulatory data sourced from MOFCOM announcements and the lanthanides.io regulatory tracker. Status current as of publication date. See China’s invisible rare earth wall for analysis of the domestic regulatory architecture.