China Rare Earth Export Curbs

Effective Dates: Immediate: October 9, 2025 – Initial controls on rare earths and related technologies, lithium batteries, cathode/anode materials
November 8, 2025: Export controls on rare earth production equipment, raw materials, superhard materials, and related technologies
December 1, 2025: Controls extend to foreign-made products containing ≥0.1% Chinese-origin rare earths
Announcement References: 55, 56, 57, 58, 61, 62 of 2025

China has expanded its export control regime on rare earth elements (REEs) and critical technologies, reinforcing its strategic dominance in global high-tech supply chains. These measures target materials essential for electric vehicles, wind turbines, semiconductors, defense systems, and AI.

Rationale:

i. Safeguard national security
ii. Fulfill international non-proliferation commitments
iii. Maintain control over strategically sensitive materials
iv. Regulate global critical supply chains

Rare Earth Elements Affected

Dual-use nature: These elements are used in both civilian and military technologies.

Provisions for Rare Earth Items & Technologies

Provisions for Lithium Battery & Cathode/Anode Materials Controls

Provisions for Advanced Computing & AI Controls

Semiconductors ≤14nm and AI systems with potential military applications require export licensing.
Military end-users prohibited; humanitarian exceptions (medical, disaster relief) allowed with MOFCOM reporting.

Provisions for Superhard Materials & Equipment Controls

Exclusions: Diamonds for decorative/jewelry purposes are not controlled.

Industry Impact

i. Supply Chain Disruptions: Potential delays and higher costs for REE-dependent industries.
ii. Sector-Specific Effects: Electronics, renewable energy, automotive, defense, and advanced manufacturing heavily impacted.
iii. Global Sourcing Shifts: Companies may seek alternative suppliers, recycling methods, or substitute materials.
iv. Strategic Timing: Announcement aligns with high-level trade talks, highlighting geopolitical leverage.

Recommendations for Businesses

Audit Supply Chains: Identify all products containing restricted rare earth elements.
Licensing Compliance: Apply for required export permits in advance.
Contingency Planning: Explore alternative sourcing, material substitutes, and stockpiling strategies.
Customs Accuracy: Declare dual-use items accurately; note control codes in customs documentation.

China’s strengthened export control measures emphasize the strategic importance of rare earths, lithium batteries, superhard materials, and related technologies. Global companies must adapt quickly to comply with regulations, secure supply chains, and mitigate operational risks.

Reference: MOFCOM