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China's rare earth export controls: status by element

Procurement and supply-chain buyers sourcing rare earths and gallium outside China

By the StrategicRawMaterial team · · 11 min read

Which rare earths does China restrict, and which need a MOFCOM licence in 2026?

As of 29 October 2026, exporters in China need a licence from the Ministry of Commerce (MOFCOM) to ship seven medium and heavy rare earths: samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium. The requirement comes from Announcement No. 18 of 2025 by MOFCOM and the General Administration of Customs (GAC), in force since 4 April 2025. It covers each element's metal, alloys, sputtering targets, oxides and compounds. It also covers samarium-cobalt magnets, and NdFeB magnets or magnet powder that contain terbium or dysprosium.[1]

On 9 October 2025, Announcement No. 57 added five more rare earths, due to take effect on 8 November 2025.[2]

On 7 November 2025, the day before, Announcement No. 70 suspended it, along with five other announcements, until 10 November 2026.[3] Those five elements have therefore never needed a licence in practice.

Lanthanum, cerium, neodymium and praseodymium are not controlled as elements in any MOFCOM announcement we found. Even so, an NdFeB magnet that contains terbium or dysprosium needs a licence.[1]

China's rare-earth export measures, element by element, as of 29 October 2026
WhatMeasureStatusWhat it covers
Samarium (Sm), gadolinium (Gd), terbium (Tb), dysprosium (Dy), lutetium (Lu), scandium (Sc), yttrium (Y)Announcement No. 18 of 2025, control codes 1C902–1C908[1]In force since 4 April 2025Metal, alloys, targets, oxides and compounds. Also Sm-Co magnets, and NdFeB magnets containing Tb or Dy.
Holmium (Ho), erbium (Er), thulium (Tm), europium (Eu), ytterbium (Yb)Announcement No. 57 of 2025, codes 1C909–1C913[2]Suspended until 10 November 2026[3]Metal, alloys, targets, crystals, magnet materials, phosphors, optical-fibre materials, oxides and compounds
Rare-earth magnets, parts containing them and some sputtering targets made outside China, when listed Chinese-origin rare earth items make up 0.1% or more of their valueAnnouncement No. 61 of 2025[4]Suspended until 10 November 2026[3]The exporter outside China would need a MOFCOM licence before exporting the goods
Rare-earth equipment and inputs; rare-earth technologiesAnnouncements No. 56 and No. 62 of 2025[5]Suspended until 10 November 2026[3]Processing equipment, auxiliary materials and technologies
All dual-use items, to Japanese military users, military uses, and any other end user or end use that helps raise Japan's military capabilityMOFCOM Announcement No. 1 of 2026[10]In force since 6 January 2026Covers the items controlled by No. 18. Anyone, anywhere, who transfers Chinese-origin dual-use items to Japanese organisations or individuals in breach of the ban is liable.
All dual-use items, to ten US entities including MP Materials and USA Rare EarthMOFCOM Announcement No. 23 of 2026[11]In force since 22 June 2026Exports banned, and ongoing exports must stop. Where an export is truly needed "in special circumstances", the exporter must apply to MOFCOM. Anyone, anywhere, is barred from passing Chinese-origin dual-use items to these entities.

What happens on 10 November 2026?

As of 29 October 2026, the only legal text on the suspension is Announcement No. 70. It suspends six October 2025 announcements (Nos. 55, 56, 57, 58, 61 and 62) "from today until 10 November 2026".[3] Four of them concern rare earths. The other two cover superhard materials (No. 55) and lithium batteries and artificial graphite anode materials (No. 58).[5] A MOFCOM spokesperson repeated that date on 9 April 2026. The spokesperson tied it to the consensus China and the United States reached in Kuala Lumpur.[6]

Two later statements bear on the date:

  • 20 May 2026: MOFCOM listed what the Kuala Lumpur arrangement covers, including "China's related export control measures".[8]
  • 28 September 2026: after the eighth round of China–US trade talks, MOFCOM said the two sides would keep working on the issue "on the basis of extending the Kuala Lumpur joint arrangement to 10 January 2027". It said it believed the two sides would find a positive solution on a further extension through high-level talks before the end of the year.[7]

Our inference, not a MOFCOM statement: the 28 September statement says the Kuala Lumpur arrangement of October 2025 suspended some of each side's tariff and non-tariff measures until 10 November 2026.[7] That is the same date on which No. 70's suspension ends.[3] Because the end dates match, and because the arrangement covers China's related export controls,[8] the extension to 10 January 2027 probably extends the rare-earth suspension too. The 28 September statement does not mention export controls or rare earths.[7] As of 29 October 2026, MOFCOM had published no numbered announcement amending No. 70. Its most recent announcements, dated 16 and 19 October 2026, do not amend No. 70.[9]

If no new announcement appears, the suspension's legal term ends on 10 November 2026. The texts do not say when the suspended rules would then take effect. No. 57 named 8 November 2025 as its start date, and No. 61 named 1 December 2025 for its main clauses. Both dates have already passed.[2][4] Until MOFCOM publishes a new announcement, that question has no official answer.

Timeline of China's export-control steps, 2023–2026

China's export-control steps relevant to rare earth and gallium buyers, 2023–2026
DateStepWhat it means for a buyer
2023-08-01Gallium and germanium export controls take effect (No. 23 of 2023)[16]Gallium exports need a licence from now on.
2024-12-01Dual-Use Items Export Control Regulations in force[12]Sets the 45-working-day licence review and allows general licences of up to 3 years.
2024-12-03No. 46 of 2024: no dual-use items for US military users or uses; gallium, germanium, antimony and superhard materials to the US "in principle" not licensed, and stricter end-user and end-use review for graphite[17]US buyers can in principle no longer get licences for Chinese gallium.
2025-04-04No. 18 of 2025: licence needed for Sm, Gd, Tb, Dy, Lu, Sc and Y[1]Every shipment of these elements, and of Dy- or Tb-containing NdFeB magnets, needs a licence.
2025-10-09Nos. 55–58, 61 and 62 announced: five more rare earths, the 0.1% rule, rare-earth equipment and technology, superhard materials, and lithium battery and graphite anode materials[2][4][5]Would have extended rare-earth controls to some goods made outside China.
2025-11-07No. 70 suspends those six announcements until 10 November 2026[3]The five added elements and the 0.1% rule never took effect.
2025-11-09No. 72 suspends the US clause on gallium, germanium, antimony, superhard materials and graphite until 27 November 2026[18]Our reading: licences for gallium to US civilian users are no longer refused in principle. The military ban stays.
2025-12-18MOFCOM says it has approved general licences for some Chinese exporters[13]Some exporters can make repeat shipments under one licence. MOFCOM has not said which exporters or products.
2026-01-06No. 1 of 2026: no dual-use items for Japanese military users, military uses, and any other end user or end use that helps raise Japan's military capability[10]Dual-use items cannot be exported to Japanese military users, or to buyers whose use helps raise Japan's military capability.
2026-02-2420 Japanese entities added to MOFCOM's control list, and 20 more on 29 June; on each date, another 20 Japanese entities put on its watch list[9][31][32]Check whether your customers or end users are on either list.
2026-06-22Ten US entities, including MP Materials and USA Rare Earth, added to the control list[11]Chinese-origin dual-use items may not be passed to them, including by resellers outside China.
2026-09-28MOFCOM: the Kuala Lumpur arrangement is to be extended to 10 January 2027[7]Probably extends the rare-earth suspension (our inference). No legal text yet.
2026-10-19No. 52 of 2026: revised procedure for customs challenges of suspected dual-use goods[14]Goods are held while customs and MOFCOM check them.
2026-11-10Legal end of the No. 70 suspension[3]Watch for a new MOFCOM announcement extending or ending the suspension.
2026-11-27Legal end of the No. 72 suspension[18]The US gallium clause could return.

How do China's controls on dysprosium and terbium affect buyers outside China?

As of 29 October 2026, every export from China of dysprosium or terbium needs a MOFCOM licence. That includes metal, alloys, targets, oxides and compounds, and NdFeB magnets that contain either element.[1] For a buyer outside China, this has five practical effects.

  1. Lead time. MOFCOM must decide within 45 working days of accepting an application. That is about nine weeks (our conversion, at five working days a week, before public holidays). The limit does not apply to cases referred to the State Council, or to the State Council and the Central Military Commission. Time spent on expert identification or site checks is also excluded.[12]
  2. Customs holds. If an exporter presents no MOFCOM licence and customs has evidence the goods may be dual-use, customs challenges the shipment. Announcement No. 52 of 19 October 2026 revised this procedure, replacing the General Administration of Customs' Announcement No. 123 of 2025. The challenged goods stay held; the exporter can ask customs to release unrelated goods on the same declaration. The exporter has 7 working days to submit documents. Customs then has 15 working days, and MOFCOM another 15 if it is asked to identify the item. Time spent submitting documents and testing the goods does not count, and complex cases have no time limit.[14]
  3. Who can buy. MOFCOM says it reviews licence applications that are "compliant and for civilian use".[8] Excluded are Japanese military users, military uses, and any other end user or end use that helps raise Japan's military capability.[10] Exports to entities on MOFCOM's control list, such as MP Materials and USA Rare Earth, are banned. Where an export is truly needed "in special circumstances", the exporter must apply to MOFCOM.[11] The ban on passing Chinese-origin items to listed entities applies to organisations in any country, so it reaches resellers outside China too.[11] For European buyers, MOFCOM said on 15 October 2026 that it would keep facilitating rare-earth licence approvals for the EU. It said it hoped the EU would reciprocate by facilitating key dual-use licence cases for exports to China.[15]
  4. General licences. China's rules allow a general licence for repeat exports to one or more end users for up to 3 years.[12] MOFCOM said on 18 December 2025 that it had approved some. It did not say which exporters or products.[13] Ask your supplier which kind of licence it holds. If it resells Chinese-origin material from outside China, check the licence chain back to the exporter.
  5. The 0.1% rule, if it returns. Under suspended Announcement No. 61, an exporter outside China would need a MOFCOM licence to export rare-earth magnets, parts containing them and some sputtering targets made outside China, when listed Chinese-origin rare earth items make up 0.1% or more of their value.[4] On our reading, that could catch a magnet made in Europe with Chinese terbium.

Has China banned gallium exports?

No. As of 29 October 2026, China has no general ban on gallium exports. Exports have needed a MOFCOM licence since 1 August 2023. This covers gallium metal, gallium nitride, gallium oxide, gallium phosphide, gallium arsenide, indium gallium arsenide, gallium selenide and gallium antimonide.[16]

Two country-specific measures go further:

  • United States. Since 3 December 2024, MOFCOM has banned dual-use items for US military users and uses. The same announcement said exports of gallium, germanium, antimony and superhard materials to the US would "in principle" not be licensed.[17] That second clause is suspended from 9 November 2025 until 27 November 2026. The military ban remains.[18]
  • Japan. Since 6 January 2026, dual-use items, gallium included, may not be exported to Japanese military users, military uses, and any other end user or end use that helps raise Japan's military capability. Anyone, anywhere, who transfers Chinese-origin dual-use items to Japanese organisations or individuals in breach of the ban is liable.[10] On 24 February and 29 June 2026, MOFCOM also put 20 Japanese entities each on its watch list. Exports to them cannot use a general licence. Each single licence application needs a risk assessment and a written commitment that the items will not be used to raise Japan's military capability, and the 45-working-day review limit does not apply.[31][32]

The gallium deadline of 27 November 2026 is separate from the rare-earth deadline of 10 November.

Where can I buy heavy rare earths outside China?

As of 29 October 2026, few companies outside China make, or are about to make, separated dysprosium or terbium oxide. They fall into three groups.

Selling today: Lynas Rare Earths (separation in Kuantan, Malaysia).

  • Lynas first produced dysprosium and terbium oxide in its 2025 financial year (to June 2025), and samarium oxide in March 2026.[20]
  • In the September 2026 quarter, reported on 29 October, it produced 23 tonnes of dysprosium and terbium ready for sale (combined), up from 19 tonnes in June. Lynas's quarterly dysprosium and terbium output has ranged from 8 to 26 tonnes over the last five quarters, and Lynas expects lower production overall in the December quarter, when its Malaysian plant shuts for about a month of planned maintenance.[24]
  • In its September 2026 quarterly report, Lynas describes itself as "the only commercial scale producer of light and heavy rare earth oxides outside of China".[24]
  • Its updated agreement with Japan Australia Rare Earths (JARE) includes "firm commitments for NdPr and heavy rare earth oxides".[20] Under the agreement of 10 March 2026, 75% of Lynas's heavy rare earth oxides are made available to Japanese industry, and JARE has a firm commitment to buy the equivalent of 50%.[30]

Qualified, not yet commercial: Energy Fuels (White Mesa Mill, Utah, US).

  • On 19 August 2026, Energy Fuels said a large Japanese magnet maker had approved its terbium oxide for commercial magnet production.[21]
  • Its commercial dysprosium and terbium circuits are under construction. They are expected to be commissioned in the fourth quarter of 2027, with design capacity of up to about 120 tonnes a year of dysprosium oxide and 20 tonnes a year of terbium oxide.[22]

Starting up: Solvay (La Rochelle, France).

  • Solvay announced on 12 November 2025 that it will supply NdPr, dysprosium and terbium oxides to the US magnet maker Noveon from 2026, partly from end-of-life materials.[23]
  • In July 2026, Solvay said industrial-scale dysprosium and terbium separation at La Rochelle would start in autumn 2026.[29] We found no announcement of the start as of 29 October 2026.

Among the rare earth separation plants being built outside China, Iluka's Eneabba refinery in Western Australia, which is to produce dysprosium and terbium oxide as well as NdPr, was 65% complete at the end of September 2026 and is due to be commissioned in 2027.[28][25] Arafura broke ground on its Nolans project in Australia's Northern Territory on 8 October 2026, and expects to spend the next three years building the mine and processing plant.[26]

Light rare earths such as NdPr oxide have more suppliers outside China: Lynas and MP Materials both report regular NdPr output.[19][27]

Request access to source heavy rare earths from suppliers outside China.

Dates to watch

  • 10 November 2026: the legal end of the No. 70 suspension, unless MOFCOM publishes an announcement extending it.[3]
  • 27 November 2026: the legal end of the No. 72 suspension, which covers gallium, germanium, antimony, superhard materials and graphite to the US.[18]
  • Before the end of 2026: MOFCOM says it believes China and the US will settle a further extension through high-level trade contacts.[7]
  • 10 January 2027: the date to which MOFCOM said the wider China–US arrangement would be extended.[7]
  • Any time: new additions to MOFCOM's control list, which in 2026 added 20 Japanese entities on each of two dates, seven EU entities in April, ten US entities in June and 14 EU entities in July, and to its watch list, which added 20 Japanese entities on each of two dates.[9][11][31][32]

Sources

  1. MOFCOM and GAC, Announcement No. 18 of 2025, export controls on some medium and heavy rare earth items, 4 April 2025. mofcom.gov.cn (opens in a new tab)
  2. MOFCOM and GAC, Announcement No. 57 of 2025, export controls on some medium and heavy rare earth items, 9 October 2025. mofcom.gov.cn (opens in a new tab)
  3. MOFCOM and GAC, Announcement No. 70 of 2025, suspension of Announcements Nos. 55–58, 61 and 62, 7 November 2025. mofcom.gov.cn (opens in a new tab)
  4. MOFCOM, Announcement No. 61 of 2025, export controls on foreign-related rare earth items, 9 October 2025. mofcom.gov.cn (opens in a new tab)
  5. MOFCOM, list of 2025 announcements (titles and dates of Nos. 55, 56, 58 and 62), checked 27 October 2026. mofcom.gov.cn (opens in a new tab)
  6. MOFCOM export control portal, spokesperson He Yadong on rare earth export controls, 9 April 2026. exportcontrol.mofcom.gov.cn (opens in a new tab)
  7. Xinhua, repost of MOFCOM's Department of American and Oceanian Affairs on the eighth round of China–US trade talks, 28 September 2026, giving MOFCOM's website as its source. news.cn (opens in a new tab)
  8. MOFCOM, Department of American and Oceanian Affairs on the preliminary outcomes of China–US trade talks, 20 May 2026. mofcom.gov.cn (opens in a new tab)
  9. MOFCOM, list of 2026 announcements, checked 29 October 2026. mofcom.gov.cn (opens in a new tab)
  10. MOFCOM, Announcement No. 1 of 2026, strengthening export controls on dual-use items to Japan, 6 January 2026. mofcom.gov.cn (opens in a new tab)
  11. MOFCOM, Announcement No. 23 of 2026, ten US entities added to the export control list, 22 June 2026. mofcom.gov.cn (opens in a new tab)
  12. State Council, Dual-Use Items Export Control Regulations (Order No. 792), promulgated 30 September 2024, in force 1 December 2024, Articles 15 and 17. mofcom.gov.cn (opens in a new tab)
  13. MOFCOM export control portal, spokesperson on approval of some general licences for rare earths, 18 December 2025. exportcontrol.mofcom.gov.cn (opens in a new tab)
  14. MOFCOM and GAC, Announcement No. 52 of 2026, customs challenges and identification of dual-use items, 19 October 2026. mofcom.gov.cn (opens in a new tab)
  15. MOFCOM, regular press conference, 15 October 2026 (rare earth export licences to the EU). mofcom.gov.cn (opens in a new tab)
  16. MOFCOM and GAC, Announcement No. 23 of 2023, export controls on gallium and germanium items, 3 July 2023, in force 1 August 2023. mofcom.gov.cn (opens in a new tab)
  17. MOFCOM, Announcement No. 46 of 2024, strengthening export controls on dual-use items to the United States, 3 December 2024. mofcom.gov.cn (opens in a new tab)
  18. MOFCOM, Announcement No. 72 of 2025, adjusting the implementation of Announcement No. 46 of 2024, 9 November 2025. mofcom.gov.cn (opens in a new tab)
  19. Lynas Rare Earths, Quarterly Activities Report for the period ended 30 June 2026, filed 22 July 2026. asx.com.au (opens in a new tab)
  20. Lynas Rare Earths, FY26 Results Announcement, filed 26 August 2026. ASX filing (opens in a new tab)
  21. Energy Fuels, "'Heavy' Rare Earths Produced by Energy Fuels Qualified for Use by Largest Permanent Magnet Manufacturer in Japan", 19 August 2026. energyfuels.com (opens in a new tab)
  22. Energy Fuels, "Commercial-Scale 'Heavy' Rare Earth Plant Now Under Construction in Utah", 29 July 2026. energyfuels.com (opens in a new tab)
  23. Solvay, "Noveon and Solvay forge partnership for light and heavy rare earth materials supply", 12 November 2025. solvay.com (opens in a new tab)
  24. Lynas Rare Earths, Quarterly Report for the period ended 30 September 2026, filed 29 October 2026. ASX filing (opens in a new tab)
  25. Iluka Resources, Quarterly Review to 30 June 2026, ASX, 28 July 2026. asx.com.au (opens in a new tab)
  26. Arafura Rare Earths, "Nolans Groundbreaking Ceremony", ASX, 9 October 2026. ASX filing (opens in a new tab)
  27. MP Materials, Second Quarter 2026 Results (Form 8-K, Exhibit 99.1), 6 August 2026. NdPr production of 840 tonnes, defined as finished and packaged NdPr oxide produced at Mountain Pass. sec.gov (opens in a new tab)
  28. Iluka Resources, Quarterly Review to 30 September 2026, ASX, 28 October 2026. ASX filing (opens in a new tab)
  29. Solvay, Q2 2026 earnings release, 29 July 2026. solvay.com (opens in a new tab)
  30. Lynas Rare Earths, ASX announcement on the enhanced JARE agreement, 10 March 2026. asx.com.au (opens in a new tab)
  31. MOFCOM, Announcement No. 12 of 2026, 20 Japanese entities added to the watch list, 24 February 2026. mofcom.gov.cn (opens in a new tab)
  32. MOFCOM, Announcement No. 28 of 2026, 20 Japanese entities added to the watch list, 29 June 2026. mofcom.gov.cn (opens in a new tab)