Executive Summary Following the October 2025 announcements of additional export controls on rare-earth elements (REEs) and their supply chain by the Chinese government, these controls have officially been suspended globally for one year. Despite US claims, there is no evidence to suggest that China
www.linkedin.com
China's partial suspension of rare-earth export controls aligns with its policies on other critical raw materials
Gareth Hatch
Gareth Hatch
Bringing critical-materials expertise to the…
Published Nov 10, 2025
Follow
Executive Summary
Following the October 2025 announcements of additional export controls on rare-earth elements (REEs) and their supply chain by the Chinese government, these controls have officially been suspended globally for one year. Despite US claims, there is no evidence to suggest that China has also suspended the original April 2025 REE export controls, with the current situation now in keeping with the Chinese approach to other critical raw materials.
Background
Those keeping an eye on the fast-changing situation concerning Chinese export controls on REEs will recall that on 9 October 2025, the Chinese Ministry of Commerce (MOFCOM) and the General Administration of Customs of China (GACC) issued a number of Announcements concerning additional controls on the exports of REEs precursors, finished products, equipment, technology and know-how. This followed the initial export controls announced in April 2025. The details were reviewed in detail in my previous Linkedin article on the topic.
I previously noted that on 1 November 2025, the White House announced that China would suspend "the global implementation" of the October 2025 REE export controls, and that
China will issue general licenses valid for exports of rare earths, gallium, germanium, antimony, and graphite for the benefit of U.S. end users and their suppliers around the world. The general license means the de facto removal of controls China imposed in April 2025 and October 2022.
Recent Developments
Apparently MOFCOM did not get the memo on this as the US statement was only partially confirmed in MOFCOM / GACC Announcement No. 70 of 2025 published on 7 November 2025, which noted that the implementation of the aforementioned Announcements No. 56, No. 57, No. 61 and No. 62 of 2025 would be suspended until 10 November 2026.
Announcement No. 70 pointedly did not include reference to Announcement No. 18 of 2025 and the initial April 2025 REE export controls, or its suspension, contradicting the White House statement. It did include reference to the suspension of the implementation of other export controls, namely those published in Announcements No. 55 [8] and No. 58 of 2025, on 9 October 2025.
Announcement No. 55 pertained to the requirement to obtain dual-use export licenses for items relating to superhard materials from 8 November 2025:
Certain synthetic-diamond micron powers and single crystals (not including such materials used for decorative purposes;
Certain synthetic-diamond wire saws and grinding wheels; and
Certain DC arc plasma-jet chemical-vapor-deposition equipment and process technology.
Announcement No. 58 pertained to the requirement to obtain dual-use export licenses for items relating to Li-ion batteries and synthetic-graphite anode materials from 8 November 2025:
Certain high energy-density Li-ion batteries, cells and battery packs;
Certain equipment for the manufacturing of Li-ion batteries and cathode materials;
Certain Li-Fe-P cathode materials, and precursors for certain other ternary cathode materials;
Synthetic-graphite anode materials, and anode materials containing mixtures of natural and synthetic graphite; and
Certain equipment, Certain equipment, processes and technologies for the manufacturing and coating of graphite-based anode materials.
On 9 November 2025, MOFCOM published Announcement No. 72 of 2025, announcing that the second paragraph of Announcement No. 46 of 2024, issued by MOFCOM on 4 December 2024, would be suspended until 27 November 2026. The aforementioned paragraph stated that:
in principle, the export of dual-use items related to gallium, germanium, antimony, and superhard materials to the United States will not be permitted; for the export of dual-use graphite items to the United States, more stringent end-user and end-use reviews will be implemented.
It should be noted that Paragraph 1 of Announcement No. 46 apparently remains in effect:
Export of dual-use items to U.S. military users or for military purposes is prohibited.
consistent with other recent announcements.
Announcement No. 72 of 2025 still left in place the export controls imposed by Announcement No. 23 of 2023 concerning gallium (Ga)- and germanium (Ge)-containing items, which came into effect on 1 August 2023, including:
Metallic Ga and certain Ga compounds (nitride, oxide, phosphide, arsenide, selenide and antimonide) as well as indium (In) Ga arsenide; and
Metallic Ge (including zone-refined Ge ingots), certain Ge compounds (dioxide, tetrachloride) and growth substrates, and zinc Ge phosphide.
Announcement No. 72 of 2025 also still left in place the export controls imposed by Announcement No. 33 of 2024 concerning antimony (Sb)-containing and other items, which came into effect on 15 September 2024, including:
Sb ores and raw materials;
Metallic Sb and certain high-purity Sb compounds (oxide, hydride, organo-Sb, InSb);
Certain gold and Sb smelting and separation technology; and
Certain equipment and components relating to the production of superhard materials including synthetic diamond and cubic boron nitride.
So, MOFCOM leaving the original April 2025 REE export controls in place, is consistent with the retention of controls on the export of items associated with other critical metals and materials - despite the US claim that the April 2025 controls had been suspended
cinea.ec.europa.eu