China Export Controls: Rare Earths, Licenses, UEL

By ChinaManufacturers.com Editorial Desk · Updated 30 October 2026 · How this page was researched

What China's export controls are

China's export controls are licensing requirements and prohibitions that the Chinese government places on the export of listed goods, technologies and services, administered by the Ministry of Commerce (MOFCOM) and enforced at the border by the General Administration of Customs (GACC). The legal foundation is the Export Control Law of the People's Republic of China, which reaches dual-use items (goods with both civilian and military uses), military and nuclear products, and other items tied to national security.

For most importers, the controls matter in one of two ways. Either the product itself is a controlled item, such as a rare-earth magnet or a gallium compound, and the Chinese exporter needs a MOFCOM license to ship it; or the product contains controlled materials, and the supplier's own access to those inputs is constrained. This page is written from the US importer's position, but the controls apply to exports to every country.

China's controls are a different system from US export controls. The US Commerce Department's Entity List and its rules on goods with a China nexus, such as the 2025 connected-vehicle rule that prohibits certain Chinese-linked vehicle software from Model Year 2027, are US measures. They restrict trade with Chinese-linked parties and products under US law. The measures on this page are China's own restrictions on what leaves China.

The legal framework

The Export Control Law was adopted by the Standing Committee of the National People's Congress on 17 October 2020 and took effect on 1 December 2020. As summarized in its Wikipedia entry (the MOFCOM and NPC texts were not retrieved for this page), the law:

requires licenses for exports of listed items;
asserts extraterritorial reach, applying to conduct outside China;
includes a "reciprocal measures" clause allowing China to respond to other countries' export controls; and
sets fines of 5 to 10 times illegal turnover where that turnover exceeds RMB 500,000, and otherwise RMB 500,000 to 5 million.

Implementing rules for dual-use items, the State Council's Dual-Use Items Export Control Regulations, are reported to have taken effect on 1 December 2024; that date was not confirmed against an official text.

In practice, a Chinese exporter of a controlled item applies to MOFCOM for a dual-use export license and supplies end-user and end-use certificates. Licenses can require declarations that the goods will not be re-exported to military users, so a foreign buyer may be asked to sign an end-use statement. The statutory review period under the 2024 regulations is reported as 45 working days; that figure is unconfirmed.

The critical-mineral controls, 2023 to 2025

Between 2023 and 2025, China added a succession of critical minerals and related products to its control lists. The timeline below gives the month each measure was announced. The months for gallium and germanium, the U.S.-specific ban, tungsten and related metals, the April 2025 rare earths and the October 2025 expansion are confirmed in the research; MOFCOM's announcement numbers and the exact effective dates were not confirmed against MOFCOM texts and are omitted.

Announced	Items controlled	Confirmation
July 2023	Gallium and germanium items	Confirmed (2023 restrictions)
October 2023	Graphite items	Month unconfirmed; graphite is named in the Nov 2025 general-license terms
August 2024	Antimony items	Month unconfirmed; antimony is named in the Nov 2025 general-license terms
December 2024	Exports of gallium, germanium, antimony and superhard materials to the United States "in principle" not permitted	Confirmed (2024 ban on exports to the US)
February 2025	Tungsten, tellurium, bismuth, molybdenum and indium items	Confirmed (4 Feb 2025 controls including tungsten)
April 2025	Seven medium and heavy rare earths (samarium, gadolinium, terbium, dysprosium, lutetium, scandium, yttrium) and related magnets	Confirmed
October 2025	Additional rare earths, rare-earth equipment and technology, lithium-battery and graphite-anode items, superhard materials, and a rule reaching foreign-made items containing Chinese-origin rare earths	Expansion confirmed; the reported 0.1% value threshold is unconfirmed

The pattern is that the controls moved down the supply chain over time. They began with raw minerals, extended to magnets and battery materials, and by October 2025 reached equipment, technology and foreign-made goods containing Chinese inputs. An importer of finished goods that never buys a mineral directly can still be exposed through its supplier's inputs.

The November 2025 suspension and general licenses

Under the US-China arrangement reached at Busan, the White House stated on 1 November 2025 that China would "suspend the global implementation of the expansive new export controls on rare earths and other measures" announced on 9 October 2025 (White House fact sheet, 1 November 2025). The same fact sheet said China would:

issue general licenses for exports of rare earths, gallium, germanium, antimony and graphite for the benefit of US end users and their suppliers around the world; and
suspend or remove the non-tariff countermeasures it had taken since 4 March 2025, including listings on its Unreliable Entity List.

Wikipedia's account of China's rare-earth industry confirms that the October 2025 package was suspended for one year and that China began issuing general licenses to selected exporters.

What the suspension did not do is equally important. The April 2025 rare-earth and magnet controls, and the 2023 and 2024 licensing requirements, were not lifted. The general-license arrangement eases them for qualifying exporters, but a license is still required. The research lists the belief that Busan removed all controls as a recurring importer error.

The November 2026 expiry and the conflicting reports

The suspension was for one year. As commonly reported, MOFCOM's implementing notice suspended the October 2025 measures until 10 November 2026, and suspended the December 2024 U.S.-specific ban until 27 November 2026. Neither date, nor the notice number, was confirmed against a MOFCOM text.

Sources disagree on whether the arrangement has been extended:

tariffstool, a secondary source, reports that the Busan truce was extended to 10 January 2027;
China Briefing, in a May 2026 update, reported that no extension had been agreed.

As of 30 October 2026, no primary instrument from MOFCOM or the US government confirming an extension was located. An importer whose product contains controlled rare earths, gallium, germanium, antimony or graphite should treat the period after 10 November 2026 as uncertain until an official notice settles it.

New controls in 2026

Controls continue to be added. MOFCOM announced on 19 October 2026, in remarks posted on 28 October 2026, export controls on shield machines (tunnel-boring machines) and related items, together with adjustments to dredger-related controls, effective 18 November 2026 (MOFCOM spokesperson remarks).

Two other 2026 developments appear in the research but are less certain. Wikipedia reports that China introduced automated, real-time controls and penalties for the rare-earth industry in 2026, citing a Spanish trade source; that report is low-confidence and unconfirmed. And the International Energy Agency reports that China announced battery-related export controls in October 2025 and then paused them for one year, a pause whose status after November 2026 depends on the same unresolved extension question.

The Unreliable Entity List

China's Unreliable Entity List (UEL) is a MOFCOM list of foreign entities that China considers to have harmed its interests. Measures against a listed entity can include bans on China-related import and export, on investment in China and on entry of personnel, and fines. The list was established under MOFCOM provisions issued in September 2020; the order number was not confirmed.

Listings have mostly targeted defense and technology companies. They include Lockheed Martin and Raytheon (February 2021) and PVH Corp. and Illumina (4 February 2025). Listings made since 4 March 2025 were to be suspended or removed under the November 2025 arrangement, according to the White House fact sheet. The current size of the list was not confirmed.

For an importer, the UEL matters mainly if it, or a customer, is a listed entity, because a listing can bar Chinese suppliers from dealing with that company. Three lists are often confused:

China's Unreliable Entity List: foreign companies China restricts.
The US Commerce Department's Entity List: parties to which US exports are restricted.
The UFLPA Entity List: producers whose goods are presumed barred from US entry under the forced-labor law.

What the controls mean for an importer

For a small importer of consumer goods, the effect is usually indirect: supply disruption and higher input costs, rather than a licensing obligation of its own. The controls bite directly in narrower cases:

the product is a controlled item, such as gallium or germanium wafers, antimony compounds, graphite anode material, rare-earth magnets or certain battery and drone components;
the supplier's inputs are controlled and the supplier cannot obtain them, or cannot obtain them on time; or
the supplier's license requires an end-use statement from the buyer.

Three practical points follow from the research. First, license lead time belongs in the purchase order schedule for any product containing a controlled item. Second, the controls reach magnets, battery materials, equipment and technology, not only raw minerals, so a bill of materials review is more informative than a check of the finished product's category. Third, the November 2026 expiry date is a scheduling risk in its own right for any order shipping after it.

Frequently asked questions

Can my Chinese supplier still ship rare-earth magnets to the US?

Yes, with a MOFCOM export license. The April 2025 controls on seven rare earths and related magnets remain in force, but under the November 2025 US-China arrangement China agreed to issue general licenses for rare-earth exports benefiting US end users and their suppliers, according to the White House fact sheet of 1 November 2025.

Are China's October 2025 export controls in effect?

No, they were suspended for one year under the November 2025 arrangement, reportedly until 10 November 2026. As of 30 October 2026, sources conflict on whether the suspension has been extended: one secondary source reports an extension to 10 January 2027, while China Briefing reported none agreed. No primary notice was located.

What is China's Unreliable Entity List?

It is a MOFCOM list of foreign entities China says have harmed its interests, which can face bans on China-related trade, investment and entry of personnel, as well as fines. Listings include Lockheed Martin, Raytheon, PVH Corp. and Illumina. Listings since 4 March 2025 were to be suspended or removed under the November 2025 arrangement.

Does China's Export Control Law apply outside China?

Yes. The Export Control Law, in effect since 1 December 2020, asserts extraterritorial jurisdiction, and the October 2025 package, now suspended, would have reached foreign-made items containing Chinese-origin rare earths. Licenses can also require foreign buyers to sign end-use statements barring re-export to military users.

How do China's export controls affect a small importer?

Usually indirectly, through supply disruption and higher input costs. Direct licensing applies only when the product is itself a controlled item, such as a rare-earth magnet, antimony compound or graphite anode material, or when the supplier cannot obtain controlled inputs. Build license lead time into orders for any product that contains them.

Which minerals does China restrict for export?

Controlled items include gallium, germanium, graphite, antimony, tungsten, tellurium, bismuth, molybdenum, indium and seven medium and heavy rare earths with related magnets, added between 2023 and April 2025. A December 2024 measure barred exports of gallium, germanium, antimony and superhard materials to the US in principle; it was reportedly suspended until 27 November 2026.

China export controls: rare earths, licenses and the UEL