China Tightens Rare-Earth Export Controls, Extending Oversight to Foreign Actors

Overview

• China’s Ministry of Commerce issued Documents No. 61 and No. 62 on Oct. 9, putting new export-control rules into effect immediately, with specified sections set to start on Dec. 1, 2025.
• The measures require licenses and end‑use notifications for technologies tied to extraction, smelting, separation, recycling, magnetic materials, and the assembly, maintenance, repair, and upgrading of production lines.
• Foreign organizations operating in China must seek export licenses, commit not to threaten China’s security, and obtain approval before providing sensitive technologies, intermediation, financing, or consultancy.
• Exports that could enable military or terrorist uses or pose national‑security risks are prohibited, with narrowly defined humanitarian, medical, and emergency exceptions subject to prior government notification and case‑by‑case review.
• Additional ministry notices reported in the coverage extend controls to certain physical goods such as rare‑earth equipment, specific metals, high‑energy‑density lithium batteries, and superhard materials, with effective dates beginning Nov. 8, while Document No. 62 also regulates transfer of processing know‑how.