Rare Earths: China Tightens Controls

🔒China’s MOFCOM issues 7 announcements tightening export controls on rare earths, superhard materials, lithium battery inputs, and more. We explain.

MOFCOM Publishes Seven Export Control Announcements on October 9, 2025

On October 9, 2025, China’s Ministry of Commerce (MOFCOM) released seven export control announcements, signaling a major tightening of China’s export control framework. The measures focus on three key areas: rare earth–related controls, newly controlled items, and additions to the Unreliable Entity List.

1. Rare Earth–Related Controls

China has for the first time expanded extraterritorial jurisdiction over rare earth materials. Highlights include:

• Products manufactured abroad containing Chinese-origin rare earths now require approval for re-export if Chinese content is 0.1% or higher.

• This threshold brings nearly all foreign products containing Chinese rare earths under Chinese control.

• Rules cover items produced overseas using Chinese-origin rare earth mining, smelting, alloying, magnet manufacturing, or recycling technologies.

Details:

https://www.mofcom.gov.cn/zcfb/blgg/art/2025/art_e1b8bcd4bcb84eba9e1adc56b4101157.html 

• “Export” now also includes licensing, investment, exhibition, R&D collaboration, consulting, and technical assistance.

Details:

https://www.mofcom.gov.cn/zcfb/blgg/art/2025/art_45be37e549f44e91a2c2b2f16389687a.html

2. Newly Controlled Items

Controls have been introduced on items critical to high-tech and new energy industries:

• Superhard materials: synthetic diamond powder, single crystals, wire saws, grinding wheels, and related DC plasma CVD equipment. See: https://www.mofcom.gov.cn/zcfb/blgg/art/2025/art_333950798cb04c7a8c517cdecf9c564c.html

• Rare earth production equipment and raw materials: centrifuges, roasting kilns, flotation reagents, extraction agents. See: https://www.mofcom.gov.cn/zcfb/blgg/art/2025/art_9ee7af86f4274dc1ad16d6d6a5e47245.html

• Middle and heavy rare earth elements: holmium, erbium, thulium, europium, and ytterbium. See: https://www.mofcom.gov.cn/zcfb/blgg/art/2025/art_1ace3f9f948845758206ad0be6869161.html

• Lithium battery and artificial graphite anode materials, essential for new energy technologies. See: https://www.mofcom.gov.cn/zcfb/blgg/art/2025/art_aacba813b5b04e79a530aee7223b74a0.html

3. Unreliable Entity List

China added 19 foreign entities to its Unreliable Entity List, continuing its policy of targeting companies deemed non-compliant with Chinese regulations or detrimental to Chinese interests.

More detail: On October 9, 2025, China’s Unreliable Entity List Working Mechanism announced the inclusion of several foreign companies, citing national sovereignty, security, and development interests. The announcement prohibits these entities from engaging in import/export activities with China, making new investments, and cooperating with Chinese organizations or individuals, including transmitting sensitive information. All measures are enforced under the Unreliable Entity List Regulations, the Foreign Trade Law, the National Security Law, and the Anti-Foreign Sanctions Law. The restrictions apply immediately and encompass multiple subsidiaries and affiliates of the listed companies worldwide.

Here’s a clear list of the foreign entities added to China’s Unreliable Entity List as of October 9, 2025:

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

See: https://www.mofcom.gov.cn/zcfb/blgg/art/2025/art_fa3dc71341524b8784bea825ef9da03e.html

Implications for Trade Compliance

These announcements have immediate consequences for global companies:

• Supply chain review: Manufacturers and importers must check if products contain Chinese-origin rare earths or newly controlled materials.

• Licensing requirements: Re-export approvals may now be required even for products produced outside China.

• Risk mitigation: Firms must implement compliance controls, track material origins, and update contracts with suppliers.

• Reputational and legal exposure: Non-compliance can result in fines, sanctions, or export restrictions.

  
  

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