China Implements New Export Controls on Rare Earth Tech, Superhard Materials, Lithium Batteries, and Artificial Graphite Anode Materials

Policy Documents Translated

MOFCOM didn’t have much rest during the holiday. On the first day back after the National Day holiday, MOFCOM issued six new export restrictions covering rare earth technologies and equipment, superhard material-related items, and lithium batteries and artificial graphite anode materials.

My understanding is that this series of export restrictions represents China building out its own export control system and fleshing out the framework of its Export Control Law. At the same time, the timing suggests this is largely a response to recent US chip restrictions on China. As the US controls exports of advanced-process chips and semiconductor equipment, China is now controlling exports of the rare earths needed to manufacture those very chips and equipment. There’s also a clear element of China stockpiling bargaining chips for upcoming negotiations with the US.

Pretty sure that MOFCOM has learned a great deal from the US chip restrictions on China, just read these two paragraphs from document 61

含有、集成或者混有原产于中国的本公告附件1第一部分所列物项在境外制造的本公告附件1第二部分所列物项，且附件1第一部分所列物项占境外制造的附件1第二部分所列物项的价值比例达到0.1%及以上的；

(1) Items listed in Part 2 of Annex 1 to this Announcement that are manufactured abroad and contain, integrate, or incorporate items listed in Part 1 of Annex 1 originating from China, where the items from Part 1 account for 0.1% or more of the value of the foreign-manufactured items in Part 2;

二、对向境外军事用户的出口申请，以及向出口管制管控名单和关注名单所列的进口商和最终用户（包括其控股50%及以上的子公司、分公司等分支机构）的出口申请，原则上不予许可。

II. Export applications to foreign military end-users, and export applications to importers and end-users (including subsidiaries and branches with 50% or more shareholding) listed on export control watch lists and attention lists, shall in principle not be permitted.

And you can find many similarities to the new “Affiliates Rule” that the US implemented on September 29, especially the “50% ownership flow-down rule.”

Besides those restrictions, MOFCOM also added Dedrone by Axon, TechInsights, and its affiliates to the Unreliable Entity List. The spokesperson commented on that:

In recent years, foreign entities including Dedrone by Axon, TechInsights and its affiliates have, despite China’s strong opposition, engaged in so-called military-technical cooperation with Taiwan, published malicious statements concerning China, and assisted foreign governments in suppressing Chinese enterprises, seriously undermining China’s national sovereignty, security, and development interests. In accordance with the Foreign Trade Law of the People’s Republic of China, the National Security Law of the People’s Republic of China, the Anti-Foreign Sanctions Law of the People’s Republic of China, and other laws, and pursuant to Article 2 of the Provisions on the Unreliable Entity List, China is holding them legally accountable for their unlawful conduct.

China has always handled Unreliable Entity List matters prudently, only targeting in accordance with law a very small number of foreign entities that endanger China’s national security. Foreign entities operating in good faith and in compliance with the law have absolutely no need for concern. The Chinese government, as always, welcomes enterprises from around the world to invest and do business in China, and remains committed to providing a stable, fair, and predictable business environment for law-abiding foreign enterprises operating in China.

Below are the documents translated:

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MOFCOM Announcement No. 61/2025: Decision on Implementing Export Controls on Foreign-Related Rare Earth Items

Issuing Authority: Security and Control Bureau
Document Number: MOFCOM Announcement No. 61/2025
Issue Date: October 9, 2025

To safeguard national security and interests, in accordance with the Export Control Law of the People’s Republic of China, the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, and other relevant laws and regulations, and with approval from the State Council of China, the following export control measures are hereby adopted:

I. Foreign organizations and individuals (hereinafter referred to as “foreign specific export operators”) must obtain dual-use item export licenses issued by the Ministry of Commerce of China before exporting the following items to countries and regions outside China:

(1) Items listed in Part 2 of Annex 1 to this Announcement that are manufactured abroad and contain, integrate, or incorporate items listed in Part 1 of Annex 1 originating from China, where the items from Part 1 account for 0.1% or more of the value of the foreign-manufactured items in Part 2;

(2) Items listed in Annex 1 to this Announcement produced abroad using technologies originating from China related to rare earth mining, smelting and separation, metal smelting, magnetic material manufacturing, or rare earth secondary resource recycling;

(3) Items listed in Annex 1 to this Announcement originating from China.

II. Export applications to foreign military end-users, and export applications to importers and end-users (including subsidiaries and branches with 50% or more shareholding) listed on export control watch lists and attention lists, shall in principle not be permitted.

III. Export applications for the following end-uses shall in principle not be permitted:

(1) Design, development, production, or use of weapons of mass destruction and their delivery systems;

(2) Terrorist purposes;

(3) Military use or enhancement of military capabilities.

IV. Export applications with end-uses for research and development or production of logic chips at 14nm and below or memory chips at 256 layers and above, as well as production equipment, testing equipment and materials for manufacturing semiconductors of the above processes, or research and development of artificial intelligence with potential military applications, shall be reviewed on a case-by-case basis.

V. For export applications with end-uses for humanitarian relief such as emergency medical care, response to public health emergencies, or natural disaster relief, foreign export operators do not need to apply for dual-use item export licenses, but shall report to the Ministry of Commerce of China via email (jingwaibaogao@mofcom.gov.cn) no later than 10 working days after export, and commit that the relevant items will not be used for purposes that endanger China’s national security and interests.

VI. Foreign specific export operators applying for dual-use item export licenses shall submit relevant documents in accordance with Article 16 of the Regulations on Export Control of Dual-Use Items of the People’s Republic of China and the requirements of the Ministry of Commerce’s dual-use item export license approval system. All documents shall be in Chinese. The approval system website is:

http://ecomp.mofcom.gov.cn

.

Foreign specific export operators may submit application documents directly or entrust enterprises, intermediary service organizations, chambers of commerce, associations, etc. located in China to handle the application. Such intermediary service organizations, chambers of commerce, or associations shall be independent legal persons or unincorporated organizations capable of independently bearing legal responsibility.

If foreign specific export operators cannot determine whether the items intended for export are items that require export licenses under this Announcement, they may consult via email (jingwaizixun@mofcom.gov.cn).

VII. Domestic export operators exporting dual-use items listed in Part 1 of Annex 1 to this Announcement shall fill in the final destination country or region as required when declaring customs and issue a “Compliance Notice” to foreign importers and end-users in accordance with the compliance guidelines attached to this Announcement.

Foreign export operators shall issue a “Compliance Notice” to the next recipient when transferring or exporting items controlled by this Announcement, in accordance with the compliance guidelines requirements of this Announcement.

VIII. Sections I(1) and I(2) of this Announcement shall be implemented from December 1, 2025. Section I(3) of this Announcement shall be implemented from the date of publication.

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MOFCOM Announcement No. 62/2025: Decision on Implementing Export Controls on Rare Earth-Related Technologies

Issuing Authority: Security and Control Bureau
Document Number: MOFCOM Announcement No. 62/2025
Issue Date: October 9, 2025

To safeguard national security and interests, in accordance with the Export Control Law of the People’s Republic of China, the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, and other relevant laws and regulations, and with approval from the State Council, the following export control measures for rare earth-related technologies and other items are hereby adopted:

I. The following items shall not be exported without permission:

(1) Technologies and their carriers related to rare earth mining, smelting and separation, metal smelting, magnetic material manufacturing, and rare earth secondary resource recycling; (Control Code: 1E902.a)

(2) Technologies for production line assembly, commissioning, maintenance, repair, and upgrading related to rare earth mining, smelting and separation, metal smelting, magnetic material manufacturing, and rare earth secondary resource recycling. (Control Code: 1E902.b)

For the export of non-controlled goods, technologies, or services, where the export operator knows that they are used for or substantially contribute to foreign rare earth mining, smelting and separation, metal smelting, magnetic material manufacturing, or rare earth secondary resource recycling activities, the operator shall apply to the Ministry of Commerce for dual-use item export licenses in accordance with Article 12 of the Export Control Law of the People’s Republic of China and Article 14 of the Regulations on Export Control of Dual-Use Items before export. Such items or services shall not be provided without permission.

The meanings and scope of “rare earth,” “smelting and separation,” “metal smelting,” and “rare earth secondary resources” referenced in this Announcement shall be implemented in accordance with relevant provisions of the Rare Earth Management Regulations of the People’s Republic of China. “Magnetic material manufacturing” technology referred to in this Announcement means samarium-cobalt, neodymium-iron-boron, and cerium magnet manufacturing technologies. Technologies and their carriers referred to in this Announcement include technology-related materials and data, such as design drawings, process specifications, process parameters, processing programs, and simulation data.

II. Export operators referred to in this Announcement include Chinese citizens, legal persons and unincorporated organizations, as well as all natural persons, legal persons and unincorporated organizations within the territory of China.

Export referred to in this Announcement means the transfer of controlled items listed in this Announcement from within the territory of the People’s Republic of China to outside the territory, or the provision to foreign organizations or individuals within or outside the territory, including trade exports as well as transfers or provisions through any means such as intellectual property licensing, investment, exchange, donation, exhibition, display, testing, teaching, joint research and development, employment or hiring, consulting, etc.

III. Export operators shall apply for export licenses to the Ministry of Commerce in accordance with Article 16 of the Regulations on Export Control of Dual-Use Items of the People’s Republic of China. When applying to export technology, export operators shall simultaneously submit a “Statement on the Transfer or Provision of Export-Controlled Technology” in accordance with Annex 1 requirements. When providing technology controlled by this Announcement to foreign organizations or individuals located within the territory of the People’s Republic of China, they shall simultaneously submit a “Statement on the Provision of Export-Controlled Technology within the Territory” in accordance with Annex 2 requirements.

Export operators shall use licenses in accordance with Article 18 of the Regulations on Export Control of Dual-Use Items of the People’s Republic of China and fulfill reporting obligations as required by the license.

IV. Export operators shall strengthen compliance awareness, understand the performance specifications and main uses of goods, technologies, and services intended for export, and determine whether they are dual-use items. If unable to determine whether the items intended for transfer or provision are items controlled by this Announcement, or unable to determine whether relevant circumstances are controlled by this Announcement, they may consult the Ministry of Commerce.

V. No entity or individual shall provide intermediary, brokerage, agency, freight, delivery, customs clearance, third-party e-commerce transaction platform, or financial services for acts violating this Announcement. Where export of items controlled by this Announcement may be involved, service providers shall proactively inquire whether the service recipient’s export activities are subject to this Announcement, whether they are applying for export licenses or have obtained licenses. Export operators who have obtained dual-use item export licenses shall proactively present their licenses to relevant service providers.

VI. Technologies that have entered the public domain, technologies in basic scientific research, or technologies necessary for ordinary patent applications are not subject to this Announcement. From the effective date of this Announcement, disclosure of technologies controlled by this Announcement that have not entered the public domain to unspecified parties without permission shall be punished in accordance with Article 34 of the Export Control Law of the People’s Republic of China.

VII. Chinese citizens, legal persons, and unincorporated organizations shall not provide any substantial assistance or support for foreign rare earth mining, smelting and separation, metal smelting, magnetic material manufacturing, or rare earth secondary resource recycling activities without permission. Violations of this Announcement shall be punished in accordance with relevant provisions of the Export Control Law of the People’s Republic of China and the Regulations on Export Control of Dual-Use Items of the People’s Republic of China.

VIII. This Announcement shall be implemented from the date of publication. The Export Control List of Dual-Use Items of the People’s Republic of China shall be updated accordingly.

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MOFCOM & GACC Announcement No. 55/2025: Decision on Implementing Export Controls on Superhard Material-Related Items

Issuing Authority: Security and Control Bureau
Document Number: MOFCOM & GACC Announcement No. 55/2025
Issue Date: October 9, 2025

In accordance with the Export Control Law of the People’s Republic of China, the Foreign Trade Law of the People’s Republic of China, the Customs Law of the People’s Republic of China, the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, to safeguard national security and interests and fulfill international non-proliferation obligations, and with approval from the State Council, export controls on the following items are hereby implemented:

I. 2C902.a. Synthetic diamond micropowder with average particle size ≤ 50 μm (Reference HS Code: 71051020)

II. 2C902.b. Synthetic diamond monocrystals with average particle size > 50 μm and ≤ 500 μm (Reference HS Code: 71051020)

Note: Item 2C902.b does not control lab-grown diamonds for decorative or jewelry purposes.

III. 2C902.c. Synthetic diamond wire saws with all of the following characteristics:

1. Wire diameter ≤ 45 μm;

2. Average diamond particle size ≤ 8 μm;

3. Breaking tension ≤ 16 N.

IV. 2C902.d. Synthetic diamond grinding wheels with all of the following characteristics (Reference HS Code: 68042110):

1. Diamond tooth hardness ≤ 30 HRB;

2. Average diamond particle size ≤ 5 μm;

3. Maximum working speed ≥ 40 m/s.

V. 2B005.b. Direct current arc plasma jet chemical vapor deposition (DCPCVD) equipment (Reference HS Code: 84798999)

VI. 2E902 Direct current arc plasma jet chemical vapor deposition (DCPCVD) process technology

Export operators exporting the above items shall apply for licenses to the competent commerce department of the State Council in accordance with relevant provisions of the Export Control Law of the People’s Republic of China and the Regulations on Export Control of Dual-Use Items of the People’s Republic of China.

Export operators shall be responsible for the authenticity of declared commodities, strengthen identification of export items. For controlled items, they must note “Dual-use item” in the remarks column of the customs declaration and list the dual-use item export control code; for items not controlled but with parameters, indicators, or performance close to controlled items, they must note “Not a controlled item” in the remarks column and fill in specific parameters and indicators. Where customs has doubts about the completeness, accuracy, and authenticity of the above information, customs will legally challenge it, and export goods will not be released during the challenge period.

This Announcement shall be officially implemented from November 8, 2025. The Export Control List of Dual-Use Items of the People’s Republic of China shall be updated accordingly.

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MOFCOM & GACC Announcement No. 56/2025: Decision on Implementing Export Controls on Certain Rare Earth Equipment and Raw/Auxiliary Material-Related Items

Issuing Authority: Security and Control Bureau
Document Number: MOFCOM & GACC Announcement No. 56/2025
Issue Date: October 9, 2025

In accordance with the Export Control Law of the People’s Republic of China, the Foreign Trade Law of the People’s Republic of China, the Customs Law of the People’s Republic of China, the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, to safeguard national security and interests and fulfill international non-proliferation obligations, and with approval from the State Council, export controls on the following items are hereby implemented:

I. 2B902 Rare Earth Production and Processing Equipment

(1) 2B902.a. Centrifugal extraction equipment for rare earth production and processing.

(2) 2B902.b. Intelligent continuous impurity removal and precipitation equipment for ion-adsorption rare earth ore with daily leachate processing capacity ≥ 5000 m³.

(3) 2B902.c. Calcining kilns for rare earth with all of the following characteristics:

1. Size range Φ1.8×20 m ~ Φ4.6×80 m;

2. Kiln cylinder lined with lining materials including graphite bricks, high alumina bricks, mullite bricks and other materials resistant to concentrated sulfuric acid, hydrofluoric acid corrosion and high temperature;

3. Reaction temperature ≤ 850 ℃.

(4) 2B902.d. Extraction tanks with mixing chamber volume 0.5~14.2 m³ for rare earth separation and purification.

(5) 2B902.e. Ion adsorption equipment for rare earth separation and purification.

(6) 2B902.f. Precipitation crystallization reaction tanks for rare earth with reaction tank volume 10~50 m³.

(7) 2B902.g. Components for items controlled by 2B902.f:

1. Precipitation crystallization agitator (Reference HS Code: 84798999);

2. Stirring paddle (Reference HS Code: 84799090);

3. Motors with output power 5.5~37 kW.

(8) 2B902.h. Resistance furnaces for rare earth with all of the following characteristics (Reference HS Code: 85141990):

1. Reaction temperature 320~650 ℃;

2. Components made of corrosion-resistant materials such as manganese steel, nickel-chromium alloy steel.

(9) 2B902.i. Any of the following equipment for rare earth metal electrolysis:

1. Electrolytic rectification equipment;

2. Feeding equipment;

3. Rare earth metal siphon furnace system;

4. Exhaust gas treatment equipment.

(10) 2B902.j. Rare earth electrolytic cells with all of the following characteristics (Reference HS Code: 85433000):

1. Cell type is refractory brick-built cell;

2. Anode is graphite material;

3. Cathode is tungsten material;

4. Current range 6000~30000 A;

5. Anode current density range 5~7 A/cm²;

6. Cathode current density range 1~2 A/cm².

(11) 2B902.k. Vacuum induction reduction furnaces with all of the following characteristics:

1. Medium frequency power supply frequency 1~8 kHz;

2. Heating temperature 0~1700 ℃;

3. Vacuum degree ≥ 1×10⁻³ Pa;

4. Smelting capacity 10~300 kg.

(12) 2B902.l. Vacuum carbon tube furnaces with all of the following characteristics:

1. Heating temperature 0~1700 ℃;

2. Vacuum degree ≥ 1×10⁻³ Pa;

3. Smelting capacity 10~300 kg.

(13) 2B902.m. Czochralski method rare earth crystal growth furnaces with all of the following characteristics (Reference HS Code: 85142000):

1. Heating method is induction heating;

2. Maximum heating temperature ≥ 2300 ℃;

3. Equipped with automatic diameter control crystal growth function.

(14) 2B902.n. Bridgman method rare earth crystal growth furnaces with all of the following characteristics (Reference HS Code: 85141990):

1. Heating method is resistance heating;

2. Maximum heating temperature ≥ 1400℃;

3. Equipped with multi-zone heating function.

(15) 2B902.o. Rare earth permanent magnet vacuum induction strip casting furnaces:

1. Batch vacuum induction strip casting furnace (Reference HS Code: 85142000);

2. Induction heating vacuum smelting furnace.

(16) 2B902.p. Components for items controlled by 2B902.o:

1. Water-cooled cable;

2. Copper roller;

3. Crucible;

4. Tilt angle controller;

5. Cooling system.

(17) 2B902.q. Rare earth permanent magnet hydrogen decrepitation furnaces:

1. Continuous atmosphere heat treatment furnace;

2. Rotating hydrogen decrepitation furnace;

3. Explosion-proof continuous hydrogen decrepitation furnace.

(18) 2B902.r. Components for items controlled by 2B902.q:

1. Valve;

2. Hydrogen gas manifold.

(19) 2B902.s. Air jet mills for rare earth permanent magnets with all of the following characteristics:

1. Particle size ≤ 5μm;

2. Total powder recovery rate ≥ 99%;

3. Oxygen content inside system ≤ 80ppm.

(20) 2B902.t. Molding presses with magnetizing fields for rare earth permanent magnets with magnetic induction intensity ≥ 1.5T.

(21) 2B902.u. Automatic hot pressing equipment for rare earth permanent magnets.

(22) 2B902.v. Cold isostatic presses for rare earth permanent magnets not controlled by 2B104 (Reference HS Code: 84798310).

(23) 2B902.w. Any of the following rare earth permanent magnet vacuum sintering furnaces with cooling time ≤ 20 min, heating temperature 500~1200 ℃, and temperature uniformity within ±3 ℃ at 1000 ℃:

1. Single horizontal sintering furnace;

2. Continuous vacuum sintering furnace;

3. Vertical sintering furnace.

(24) 2B902.x. Equipment for rare earth magnetic material processing:

1. Multi-wire cutting machine;

2. Laser cutting equipment;

3. Automatic gluing machine;

4. Vertical grinder;

5. Double-sided grinder;

6. End face grinder;

7. Through-feed grinder.

(25) 2B902.y. Grain boundary diffusion equipment:

1. Physical vapor deposition magnetron sputtering coating equipment (Reference HS Code: 84798999);

2. Rare earth permanent magnet vacuum diffusion furnace;

3. Screen printing device for rare earth permanent magnets.

(26) 2B902.z. Shaft kilns with size range ≥ Φ19×21 m for rare earth secondary resource recycling.

II. 1C914 Rare Earth Raw and Auxiliary Material-Related Items

(1) 1C914.a. Rare earth ores (Reference HS Code: 25309020):

1. Bastnasite;

2. Monazite;

3. Ion-adsorption rare earth ore.

(2) 1C914.b. Rare earth ore flotation reagents containing hydroxamic acid or phosphate ester collectors.

(3) 1C914.c. Extractants for rare earth production:

1. P507: 2-ethylhexyl phosphonic acid mono-2-ethylhexyl ester (CAS 14802-03-0) (Reference HS Code: 29319000);

2. P204: Bis(2-ethylhexyl) phosphate (CAS 298-07-7) (Reference HS Code: 29199000);

3. Naphthenic acid (CAS 1338-24-5) (Reference HS Code: 38249999);

4. N235: Trioctyldecylamine (CAS 68814-95-9) (Reference HS Code: 38249999);

5. C272: Bis(2,4,4-trimethylpentyl)phosphinic acid (CAS 83411-71-6).

Export operators exporting the above items shall apply for licenses to the competent commerce department of the State Council in accordance with relevant provisions of the Export Control Law of the People’s Republic of China and the Regulations on Export Control of Dual-Use Items of the People’s Republic of China.

Export operators shall be responsible for the authenticity of declared commodities, strengthen identification of export items. For controlled items, they must note “Dual-use item” in the remarks column of the customs declaration and list the dual-use item export control code; for items not controlled but with parameters, indicators, or performance close to controlled items, they must note “Not a controlled item” in the remarks column and fill in specific parameters and indicators. Where customs has doubts about the completeness, accuracy, and authenticity of the above information, customs will legally challenge it, and export goods will not be released during the challenge period.

This Announcement shall be officially implemented from November 8, 2025. The Export Control List of Dual-Use Items of the People’s Republic of China shall be updated accordingly.

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MOFCOM & GACC Announcement No. 57/2025: Decision on Implementing Export Controls on Certain Medium-Heavy Rare Earth-Related Items

Issuing Authority: Security and Control Bureau
Document Number: MOFCOM & GACC Announcement No. 57/2025
Issue Date: October 9, 2025

In accordance with the Export Control Law of the People’s Republic of China, the Foreign Trade Law of the People’s Republic of China, the Customs Law of the People’s Republic of China, the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, to safeguard national security and interests and fulfill international non-proliferation obligations, and with approval from the State Council, export controls on the following items are hereby implemented:

I. 1C909 Holmium-Related Items

(1) 1C909.a. Metallic holmium, holmium-containing alloys and related products:

1. Metallic holmium (Reference HS Code: 28053019).

2. Holmium-containing alloys:
   a. Holmium-copper alloy;
   b. Magnesium-holmium alloy;
   c. Holmium-iron alloy.

3. Holmium-containing target materials:
   a. Holmium target;
   b. Holmium-copper alloy target.

4. Holmium-containing permanent magnet materials.

5. Holmium-containing crystal materials.

6. Holmium-containing magnetic refrigeration materials.

7. Holmium-containing magnetostrictive materials.

(2) 1C909.b. Holmium oxide and its mixtures.

(3) 1C909.c. Holmium-containing compounds and their mixtures.

II. 1C910 Erbium-Related Items

(1) 1C910.a. Metallic erbium, erbium-containing alloys and related products:

1. Metallic erbium (Reference HS Code: 28053019).

2. Erbium-containing alloys:
   a. Erbium-aluminum alloy;
   b. [Reserved].

3. Erbium-containing target materials:
   a. Erbium target;
   b. [Reserved].

4. Erbium-containing crystal materials.

5. Erbium-containing optical fiber materials.

6. Erbium-containing hydrogen storage materials.

7. Erbium-containing ceramic materials.

(2) 1C910.b. Erbium oxide and its mixtures.

(3) 1C910.c. Erbium-containing compounds and their mixtures.

III. 1C911 Thulium-Related Items

(1) 1C911.a. Metallic thulium, thulium-containing alloys and related products:

1. Metallic thulium (Reference HS Code: 28053019).

2. Thulium-containing target materials:
   a. Thulium target;
   b. [Reserved].

3. Thulium-containing crystal materials.

4. Thulium-containing luminescent materials.

(2) 1C911.b. Thulium oxide and its mixtures.

(3) 1C911.c. Thulium-containing compounds and their mixtures.

IV. 1C912 Europium-Related Items

(1) 1C912.a. Metallic europium, europium-containing alloys and related products:

1. Metallic europium (Reference HS Code: 28053019).

2. Europium-containing alloys:
   a. Magnesium-europium alloy;
   b. [Reserved].

3. Europium-containing target materials:
   a. Europium target;
   b. [Reserved].

4. Europium-containing luminescent materials:
   a. Phosphors;
   b. [Reserved].

5. Europium-containing crystal materials.

6. Europium-containing hydrogen absorption materials.

(2) 1C912.b. Europium oxide and its mixtures.

(3) 1C912.c. Europium-containing compounds and their mixtures.

V. 1C913 Ytterbium-Related Items

(1) 1C913.a. Metallic ytterbium, ytterbium-containing alloys and related products:

1. Metallic ytterbium (Reference HS Code: 28053019).

2. Ytterbium-containing target materials:
   a. Ytterbium target;
   b. [Reserved].

3. Ytterbium-containing crystal materials.

4. Ytterbium-containing optical fiber materials.

5. Ytterbium-containing thermal barrier coating materials.

(2) 1C913.b. Ytterbium oxide and its mixtures.

(3) 1C913.c. Ytterbium-containing compounds and their mixtures.

Notes:

1. Alloys controlled by items 1C909.a.2, 1C910.a.2, 1C912.a.2 include forms such as ingots, blocks, bars, wires, sheets, rods, plates, tubes, particles, and powders.

2. Target materials controlled by items 1C909.a.3, 1C910.a.3, 1C911.a.2, 1C912.a.3, 1C913.a.2 include forms such as sheets and tubes.

3. Permanent magnet materials controlled by item 1C909.a.4 include magnets or magnetic powders.

4. Oxides, compounds and their mixtures controlled by items 1C909, 1C910, 1C911, 1C912, 1C913 include but are not limited to forms such as powders.

Export operators exporting the above items shall apply for licenses to the competent commerce department of the State Council in accordance with relevant provisions of the Export Control Law of the People’s Republic of China and the Regulations on Export Control of Dual-Use Items of the People’s Republic of China.

Export operators shall be responsible for the authenticity of declared commodities, strengthen identification of export items. For controlled items, they must note “Dual-use item” in the remarks column of the customs declaration and list the dual-use item export control code; for items not controlled but with parameters, indicators, or performance close to controlled items, they must note “Not a controlled item” in the remarks column and fill in specific parameters and indicators. Where customs has doubts about the completeness, accuracy, and authenticity of the above information, customs will legally challenge it, and export goods will not be released during the challenge period.

This Announcement shall be officially implemented from November 8, 2025. The Export Control List of Dual-Use Items of the People’s Republic of China shall be updated accordingly.

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MOFCOM & GACC Announcement No. 58/2025: Decision on Implementing Export Controls on Lithium Battery and Artificial Graphite Anode Material-Related Items

Issuing Authority: Security and Control Bureau
Document Number: MOFCOM & GACC Announcement No. 58/2025
Issue Date: October 9, 2025

In accordance with the Export Control Law of the People’s Republic of China, the Foreign Trade Law of the People’s Republic of China, the Customs Law of the People’s Republic of China, the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, to safeguard national security and interests and fulfill international non-proliferation obligations, and with approval from the State Council, export controls on the following items are hereby implemented:

I. Lithium Battery-Related Items

(1) 3A001 Rechargeable lithium-ion batteries (including cells and battery packs) with gravimetric energy density ≥ 300 Wh/kg (Reference HS Code: 85076000).

(2) 3B901.a. Equipment for manufacturing rechargeable lithium-ion batteries:

1. Winding machine (Reference HS Code: 84798999);

2. Stacking machine (Reference HS Code: 84798999);

3. Electrolyte filling machine (Reference HS Code: 84798999);

4. Hot press machine;

5. Formation and capacity grading system;

6. Capacity grading cabinet.

(3) 3E901.a. Technology for producing items controlled by 3A001.

II. Cathode Material-Related Items

(1) 3C901.a.1. Lithium iron phosphate cathode materials with compacted density ≥ 2.5 g/cm³ and specific capacity ≥ 156 mAh/g (Reference HS Code: 28429040).

(2) 3C901.a.2. Precursor-related items for ternary cathode materials:

a. Nickel cobalt manganese hydroxide (Reference HS Code: 28539030);
b. Nickel cobalt aluminum hydroxide (Reference HS Code: 28539050).

(3) 3C901.a.3. Lithium-rich manganese-based cathode materials.

(4) 3B901.b. Equipment for manufacturing rechargeable lithium-ion battery cathode materials:

1. Roller kiln;

2. High-speed mixer;

3. Sand mill;

4. Air jet mill.

III. Graphite Anode Material-Related Items

(1) 3C901.b.1. Artificial graphite anode materials.

(2) 3C902.b.2. Mixed artificial graphite and natural graphite anode materials.

(3) 3B901.c.1. Granulation process equipment for producing graphite anode materials:

a. Vertical granulation kettle with granulation volume ≥ 5 m³;
b. Continuous granulation kettle with granulation volume ≥ 5 m³.

(4) 3B901.c.2. Graphitization equipment for producing graphite anode materials:

a. Box furnace;
b. Acheson furnace;
c. Internal series furnace;
d. Continuous graphitization furnace.

(5) 3B901.c.3. Coating modification equipment for producing graphite anode materials:

a. Fusion coating equipment with volume > 300 L;
b. Spray drying equipment with volume > 60 m³;
c. Chemical vapor deposition (CVD) rotary kiln with barrel diameter > 0.5 m.

(6) 3E901.b. Processes and technologies for producing graphite anode materials:

1. Granulation process;

2. Continuous graphitization technology;

3. Liquid phase coating technology.

Export operators exporting the above items shall apply for licenses to the competent commerce department of the State Council in accordance with relevant provisions of the Export Control Law of the People’s Republic of China and the Regulations on Export Control of Dual-Use Items of the People’s Republic of China.

Export operators shall be responsible for the authenticity of declared commodities, strengthen identification of export items. For controlled items, they must note “Dual-use item” in the remarks column of the customs declaration and list the dual-use item export control code; for items not controlled but with parameters, indicators, or performance close to controlled items, they must note “Not a controlled item” in the remarks column and fill in specific parameters and indicators. Where customs has doubts about the completeness, accuracy, and authenticity of the above information, customs will legally challenge it, and export goods will not be released during the challenge period.

This Announcement shall be officially implemented from November 8, 2025. The Export Control List of Dual-Use Items of the People’s Republic of China shall be updated accordingly.

Unreliable Entity List Working Mechanism Announcement on Adding Counter Unmanned Aircraft Systems Companies and Other Foreign Entities to the Unreliable Entity List

Issuing Authority: Security and Control Bureau
Document Number: Unreliable Entity List Working Mechanism [2025] No. 10
Issue Date: October 9, 2025

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UNRELIABLE ENTITY LIST WORKING MECHANISM

ANNOUNCEMENT

No. 10 of 2025

To safeguard national sovereignty, security, and development interests, in accordance with the Foreign Trade Law of the People’s Republic of China, the National Security Law of the People’s Republic of China, the Anti-Foreign Sanctions Law of the People’s Republic of China, and other relevant laws, the Unreliable Entity List Working Mechanism has decided, pursuant to Articles 2, 8, and 10 of the Provisions on the Unreliable Entity List, to add Dedrone by Axon, TechInsights and its affiliates, and other foreign entities to the Unreliable Entity List, and to adopt the following measures:

I. The above-mentioned entities are prohibited from engaging in import and export activities related to China;

II. The above-mentioned entities are prohibited from making new investments within the territory of China;

III. Organizations and individuals within the territory of China are prohibited from engaging in transactions, cooperation, and other activities with the above-mentioned entities, particularly from transmitting data to or providing sensitive information to the above-mentioned entities.

For matters not covered in this Announcement, the Provisions on the Unreliable Entity List shall apply.

This Announcement shall be implemented from the date of publication.

Attachment: Foreign Entities Added to the Unreliable Entity List

Unreliable Entity List Working Mechanism
(Sealed on behalf of the Ministry of Commerce)
October 9, 2025

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ATTACHMENT

Foreign Entities Added to the Unreliable Entity List

1. Dedrone by Axon

2. DZYNE Technologies

3. Elbit Systems of America, LLC

4. Epirus, Inc.

5. AeroVironment, Inc.

6. Exelis Inc.

7. Alliant Techsystems Operations LLC

8. BAE Systems, Inc.

9. Teledyne FLIR, LLC

10. VSE Corporation

11. Cubic Global Defense

12. Recorded Future, Inc.

13. Halifax International Security Forum

14. TechInsights Inc. and its affiliates:

    • TechInsights Inc.

    • TechInsights Europe Limited

    • TechInsights Europe Sp z o.o.

    • TechInsights Japan KK

    • TechInsights USA Inc.

    • TechInsights Korea Co. Ltd.

    • TechInsights Market Analysis Limited

    • SARL Strategy Analytics

    • Strategy Analytics GmbH Market Research and Management Consulting

    • SARI Strategy Analytics Private Limited