China Rare Earth Export Ban: Minerals, Licenses, and Penalties

China’s rare earth export ban is not a single measure but a stack of restrictions built up between August 2023 and mid-2025, ranging from license requirements on critical minerals to outright prohibitions on shipping gallium, germanium, antimony, and superhard materials to the United States. Seven medium and heavy rare earths now require export licenses that are automatically denied for military end uses, and the refining and magnet-making technologies needed to process these materials outside China have been blocked from export as well. If you buy, sell, or manufacture with any of these inputs, the rules that apply to you depend on the specific material, the destination country, and the end user.

Timeline of the Rollout

The controls arrived in waves. Gallium and germanium license requirements took effect on August 1, 2023.¹ Graphite controls followed on December 1, 2023, covering natural flake and synthetic spheroidized products.² That same month, the Catalogue of Technologies Prohibited or Restricted from Export was updated to ban transfers of rare earth refining and magnet manufacturing know-how.

Antimony controls took effect September 15, 2024. On December 1, 2024, China consolidated its fragmented control lists into a single unified export control list.² Two days later, on December 3, 2024, the Ministry of Commerce (MOFCOM) issued Announcement No. 46, imposing an outright ban on exporting gallium, germanium, antimony, and superhard materials to the United States.³

February 2025 brought controls on tungsten, tellurium, bismuth, molybdenum, and indium.⁴ In April 2025 came the biggest escalation: export controls on seven medium and heavy rare earths.⁵ The technology catalogue was updated again in July 2025 to restrict lithium-ion battery cathode preparation and to tighten controls on gallium extraction techniques.⁶

The US-Specific Ban

The harshest treatment applies to shipments to the United States. MOFCOM Announcement No. 46 of 2024 created two layers of prohibition:³

Exports of gallium, germanium, antimony, and superhard materials to the United States are not permitted.
Exports of any dual-use items to US military users or for military uses are banned regardless of material type.

Announcement No. 46 also carries an anti-circumvention clause. Any organization or individual in any country that transfers Chinese-origin controlled materials to a US entity in violation of these rules faces legal liability under Chinese law.³ A Japanese or European intermediary that re-exports Chinese-origin gallium to a US buyer can be pursued by Chinese authorities and cut off from future trade.

The Seven Medium and Heavy Rare Earths

The April 2025 rare earth controls target samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium.⁷ These elements are scarcer than light rare earths and require complex separation processes. China has historically controlled roughly 99 percent of global heavy rare earth processing capacity.

The item lists are granular. For each element, the restricted categories include the pure metal, alloys, sputtering targets, oxides, chemical compounds, and permanent magnet materials incorporating that element. Dysprosium-containing and terbium-containing neodymium-iron-boron magnets are specifically listed, and those are the magnets used in electric vehicle motors, wind turbines, and guided munitions.⁷ Samarium cobalt permanent magnets, the high-temperature magnets used in aerospace and military systems, are similarly controlled.⁵

Starting December 1, 2025, companies with any affiliation to foreign militaries are largely denied export licenses for these materials, and any request identifying a military purpose is automatically rejected. The licensing framework also extends to foreign-produced rare earth magnets and certain semiconductor materials that contain at least 0.1 percent heavy rare earth elements sourced from China. That threshold reaches outside China’s borders: a magnet manufactured in Japan or Germany using even a trace amount of Chinese-origin rare earth material falls within the scope of the controls, and manufacturers must prove the provenance of every input or risk losing Chinese supply entirely.

Other Controlled Minerals

Gallium and germanium have moved through both layers of restriction. Since August 2023, exporters have needed a license from MOFCOM to ship either material anywhere.¹ Since December 2024, shipments to the United States are banned outright.³

Graphite controls cover natural flake products (including spherical and expanded graphite) and high-purity synthetic graphite, both essential for lithium-ion battery anodes.⁸ For US-bound shipments, stricter end-user and end-use verification applies.³ Antimony, used to harden lead in ammunition and as a flame retardant in military equipment, is licensed globally and banned for the United States. Tungsten, molybdenum, tellurium, bismuth, and indium sit under the February 2025 license regime, covering armor-piercing munitions, aerospace alloys, and advanced electronics.⁴

The Technology Transfer Bans

Raw material access is only part of the story. In December 2023, China updated its Catalogue of Technologies Prohibited or Restricted from Export to ban transfers of rare earth extraction and separation methods, the proprietary processes that turn raw ore into purified oxides.⁹ The same update covered the manufacturing technology for samarium-cobalt, neodymium-iron-boron, and cerium permanent magnets, including chemical formulas, process software, and the specialized pressing and sintering equipment used in production.

Even if a foreign buyer secures rare earth ore from a non-Chinese source, it cannot legally license Chinese refining technology to process it. The July 2025 catalogue update added lithium-ion battery cathode material preparation, including lithium iron phosphate processes, and further tightened controls on gallium metal extraction.⁶ Prohibited technologies cannot be exported at all; restricted technologies require export licenses.¹⁰

How the Export License Process Works

For materials that are controlled but not outright banned, exporters apply to MOFCOM for a dual-use item export license under the Export Control Law of the People’s Republic of China. The central document is an end-user and end-use certificate. Article 15 requires the exporter to submit certificates identifying the final recipient and intended use, issued by the end user itself or by a government agency in the buyer’s country.¹¹

Applications also include technical specifications (purity, physical form, quantity), the buyer’s legal registration details, and the underlying contracts. The standard review period is 45 business days. Applications involving buyers on MOFCOM’s watch list are not bound by that timeframe. The Regulation on Export Control of Dual-Use Items, which took effect December 1, 2024, formalized much of this process. Once a license is issued, customs officials verify at the point of exit that the cargo matches the approved specifications.

Penalties for Violations

Fines scale with the size of the illegal transaction. Exporting controlled items without approval, exceeding a license’s scope, or shipping prohibited items triggers fines of five to ten times the illegal turnover when that turnover exceeds RMB 500,000 (roughly $70,000). Where turnover is lower or absent, fines range from RMB 500,000 to RMB 5 million. Serious cases can bring suspended operations and permanent loss of export qualification. Shipping companies, customs brokers, payment processors, and platforms that knowingly assist violations face their own penalties.¹¹ Criminal prosecution is available for the most serious violations, with prison terms governed by China’s Criminal Law rather than the Export Control Law itself.

What This Means for Defense and Clean Energy Buyers

Rare earth elements are embedded in fighter jets, submarines, cruise missiles, radar systems, unmanned aerial vehicles, and precision-guided munitions. The magnets that drive electric motors in those systems rely on the heavy rare earths now under Chinese control. With any export license application identifying a military end use rejected automatically, defense contractors are left to find alternative supply or redesign around different materials.

The clean energy sector faces the same pinch through a different door. Electric vehicle motors, wind turbine generators, and advanced battery systems depend on rare earth permanent magnets and graphite anodes sourced primarily from China. Automakers and energy companies are working to qualify alternative sources, but new mining and refining capacity takes years to build. Australia, the United States, and several African nations hold rare earth deposits, though processing infrastructure outside China remains a small fraction of global demand. The 0.1 percent threshold on Chinese-origin rare earth content in foreign-made magnets makes the provenance of every input a compliance question in its own right.

1
U.S. International Trade Commission. Germanium and Gallium: U.S. Trade and Chinese Export Controls
2
European Commission. Access2Markets Barrier – Export Restrictions on Artificial Graphite Products
3
Center for Security and Emerging Technology. Ministry of Commerce Notice 2024 No. 46: Notice Concerning Strengthening Controls on Exports of Relevant Dual-Use Items to the United States
4
International Energy Agency. Decision to Implement Export Controls on Tungsten, Tellurium, Bismuth, Molybdenum and Indium Related Items
5
International Energy Agency. Export Controls on Certain Medium and Heavy Rare Earth Items
6
State Council Information Office. China Revises Catalog of Technologies Subject to Export Controls
7
Ministry of Commerce People’s Republic of China. Announcement No. 18 of 2025 – Decision to Implement Export Control on Some Medium and Heavy Rare Earth Related Items
8
International Energy Agency. Announcement on the Optimisation and Adjustment of Temporary Export Control Measures for Graphite Items
9
Center for Security and Emerging Technology. Chinese Catalogue of Technologies Prohibited or Restricted from Export
10
Center for Security and Emerging Technology. Chinese Catalogue of Technologies Prohibited or Restricted from Export (July 2025)
11
National People’s Congress of the People’s Republic of China. Export Control Law of the People’s Republic of China