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China's export controls on dual-use and critical minerals have tightened sharply since 2024. If your supplier ships rare earth magnets, gallium, germanium, antimony, or similar items, they must hold a MOFCOM export license.
China's modern controls rest on the Export Control Law (effective December 2020) and the 2024 Regulations on the Export Control of Dual-Use Items, administered by the Ministry of Commerce (MOFCOM) together with the General Administration of Customs (GACC). The system uses a control list, temporary controls, and catch-all controls for sensitive end uses.
The 2025 Catalogue of Goods Subject to Export License Administration, jointly issued by MOFCOM and GACC and effective 1 January 2025, covers 43 categories. It includes rare earths, tungsten, antimony, tin, magnesium, fluorspar, indium, and related products that require an export license.
| Date | Addition |
|---|---|
| 2023 | Gallium and germanium controls introduced |
| 2024 | Antimony added to the unified control list |
| Early 2025 | Indium, bismuth, tungsten, tellurium, molybdenum added |
| April 2025 | Seven medium and heavy rare earths (samarium, gadolinium, terbium, dysprosium, yttrium, scandium, lutetium) plus neodymium-iron-boron magnets containing terbium or dysprosium |
| October 2025 | Five more heavy rare earths and rare-earth processing equipment; extraterritorial elements introduced (suspended until 10 November 2026 after the Busan understanding) |
Under Article 49 of the 2024 dual-use regulation, China can require authorization for items located outside China: Chinese-origin dual-use items already exported, foreign-made items containing designated Chinese inputs above a 0.1 percent value threshold, and foreign-made items produced with designated Chinese technology.
Exporting controlled dual-use items without a license can bring administrative fines of five to ten times the business turnover, and criminal liability for smuggling - above one million RMB in value this can mean five or more years imprisonment. The exposure is real, so confirm licensing before booking.
No. Only items on the control list or under a temporary control require a dual-use export license; routine commercial goods do not.
Neodymium-iron-boron magnets containing terbium or dysprosium are controlled. Your supplier needs an export license even when the magnet is built into finished goods.
It varies by item and end-use review. Plan for meaningful lead time and confirm with the supplier before production.
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