China Rare Earth Export Controls

PRC Export Control Law — Rare Earth Elements, Equipment & Technologies (MOFCOM Announcements 18, 56, 57, 61, 62 of 2025)

China Controls 90% of Rare Earth Processing. Do You Know Where the Rare Earths in Your Products Come From?

China's rare earth export controls require MOFCOM licensing for 12 controlled elements, their compounds, alloys, magnets, and target materials. Extraterritorial provisions cover products made outside China containing Chinese-origin rare earths above 0.1% by value. License review takes 45 working days—if approved at all.

Certivo automates rare earth origin tracking from supplier declaration to export license documentation.

12 Rare earth elements subject to MOFCOM export licensing
0.1% De minimis value threshold triggering extraterritorial controls
45 days MOFCOM export license review period

Regulation Overview

Jurisdiction: People's Republic of China (with extraterritorial reach to foreign-made products)
Regulatory Body: Ministry of Commerce (MOFCOM) / General Administration of Customs (GAC)
Regulation Number: PRC Export Control Law; Dual-Use Items Regulations; MOFCOM Announcements 18, 56, 57, 61, 62 (2025)
Effective Date: April 4, 2025 (Announcement 18); October 9, 2025 (Announcements 55–62); October 2025 controls suspended until November 10, 2026
Official Source: http://www.mofcom.gov.cn
Key Threshold: 0.1% by value of Chinese-origin rare earth content in foreign-made products

What Are China's Rare Earth Export Controls?

China's rare earth export controls are a series of escalating MOFCOM announcements that require export licenses for controlled rare earth elements, their compounds, alloys, permanent magnets, sputtering targets, processing equipment, and related technologies. For supply chain compliance teams, these controls mean tracking Chinese-origin rare earth content across every component and supplier tier.

Announcement 18 (April 2025) imposed licensing on seven medium and heavy rare earth elements—samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium—along with all related oxides, alloys, compounds, mixtures, and magnet materials. This remains in force. The October 2025 announcements added five more elements and introduced extraterritorial provisions, though these were suspended until November 2026.

Rare earth compliance requires component-level origin data—element identification, Chinese-origin content percentages, and end-use documentation—from every supplier. When controls shift, your entire portfolio requires reassessment against updated MOFCOM requirements.

Key Components / Sub-Frameworks

Obligation

• MOFCOM license required for all exports; remains in force
• Announcement 18 (Apr 2025): Export licensing for 7 medium/heavy rare earth elements and derivatives
  • Obligation: License required if Chinese-origin rare earth content ≥0.1% by value (suspended until Nov 2026)
• Announcement 61 (Oct 2025): Extraterritorial controls on foreign-made products containing Chinese-origin rare earths
  • Obligation: License required for equipment exports (suspended until Nov 2026)
• Announcement 56 (Oct 2025): Export controls on rare earth production and processing equipment
• Announcement 62 (Oct 2025): Export controls on rare earth technologies
• Obligation: Cascading restrictions through corporate family structures

50% Affiliates Rule

Presumptive denial for entities ≥50% owned by Export Control List parties

Obligation

Applies to all controlled rare earth items; not suspended

Military End-Use Prohibition

Categorical ban on exports to foreign military users

October 2025 Controls Suspended Until November 2026—But Announcement 18 Licensing Remains Fully in Force

The April 2025 licensing requirements for seven rare earth elements and all derivative products are active today. The October 2025 extraterritorial provisions are suspended until November 10, 2026—not withdrawn. Companies should prepare now for potential reinstatement.

Key Compliance Requirements

Who Must Comply

• Chinese exporters of controlled rare earth elements and products
• Foreign importers purchasing controlled rare earths from Chinese suppliers
• Non-Chinese manufacturers using Chinese-origin rare earth materials in their products
• Companies re-exporting products containing Chinese-origin rare earths to third countries
• Importers and distributors supplying rare earth products to defense or military end users
• Any entity in the supply chain handling products with controlled rare earth content

Key Thresholds

• 0.1% by value: Chinese-origin rare earth content triggering extraterritorial license requirement
• 45 working days: Standard MOFCOM export license review period
• 50% ownership: Affiliate threshold for presumptive license denial
• One batch, one license: Separate license application required for each shipment

Core Obligations

1. Export Licensing (Announcement 18)
   Obtain MOFCOM license to export 7 controlled rare earth elements and all derivatives
   DEADLINE: In force since April 4, 2025

2. End-Use Documentation
   Provide detailed end-user profiles, intended applications, and non-transfer commitments
   DEADLINE: Required with every license application

3. Compliance Notice Regime
   Disclose origin, composition, and transfer chain for all controlled materials
   DEADLINE: At time of export and re-export

4. Military End-Use Screening
   Verify no controlled rare earths reach foreign military end users or end uses
   DEADLINE: Ongoing; presumptive denial applies

5. Extraterritorial Licensing (Suspended)
   Obtain MOFCOM license for foreign-made products containing ≥0.1% Chinese-origin rare earths
   DEADLINE: Suspended until November 10, 2026

Rare Earth Export Control-Specific Pain Points

The Origin Traceability Gap

Your product contains NdFeB permanent magnets sourced from a Japanese supplier—but the magnet contains Chinese-origin dysprosium. Under Announcement 18, that triggers MOFCOM licensing. Under the extraterritorial provisions, re-export requires a license too. You have no visibility into rare earth origin at the element level across your BOM.

The 45-Day License Bottleneck

MOFCOM operates a one-batch, one-license system. Each shipment requires a separate application with six sets of documentation, including end-user profiles and production details. Review takes 45 working days minimum. Your production line cannot wait 45 days for every rare earth shipment—and delays compound across your supply chain.

The 0.1% De Minimis Trap

The extraterritorial provisions apply at 0.1% by value of Chinese-origin rare earth content. A small rare earth additive in a component deep in your assembly could trigger full MOFCOM licensing obligations for your finished product. Without element-level origin tracking across your supply chain, you cannot determine exposure.

The Geopolitical Whiplash

Controls imposed in April. Expanded in October. Suspended in November. Reinstated provisions possible in late 2026. Your compliance posture must adapt to regulatory shifts measured in weeks, not years. Manual tracking cannot keep pace with the speed of China's rare earth policy changes.

Certivo in Action

Certivo in Action—Rare Earth Workflow

GET EVIDENCE IN
Collect Rare Earth Origin Declarations from Every Supplier—Without the Chasing
CORA launches targeted campaigns to collect element-level rare earth origin data, Chinese-content declarations, and end-use attestations from suppliers across all tiers.

• Launch rare earth origin campaigns to hundreds of suppliers with one click
• CORA-powered outreach in suppliers' native languages, including Mandarin
• Accept any format: PDFs, Excel, supplier portals, IMDS exports, freeform responses
• Track response rates and escalate non-responders automatically

MAKE SENSE OF IT

Know Instantly Which Products Contain Chinese-Origin Rare Earths Above Controlled Thresholds
CORA extracts element-level rare earth data from supplier declarations, maps Chinese-origin content against MOFCOM controlled lists, and flags products triggering licensing obligations.

• CORA parses declarations to extract rare earth elements, origin countries, and content percentages
• Automatic validation against all 12 MOFCOM-controlled elements and derivatives
• Real-time alerts when regulatory changes affect your product portfolio
• De minimis threshold calculations at the product level per MOFCOM guidance

⚠️

PROVE COMPLIANCE OUT

Generate License Support Documentation and Customer Evidence in Hours, Not Weeks
Produce end-use certificates, origin attestations, and customer-facing rare earth compliance packages instantly from validated supplier data.

• One-click end-use documentation packages for MOFCOM license applications
• Pre-formatted origin attestations with element-level traceability
• Customer-specific rare earth compliance certificates with full audit chain
• Complete audit trail for every supplier declaration, validation, and response

One Supplier Submission. Validation Against All 12 Controlled Elements. Audit-Ready in Hours.

Certivo collects supplier rare earth declarations, extracts element-level origin data, validates against MOFCOM controlled lists and de minimis thresholds, and generates license-support documentation automatically. When China modifies export controls, Certivo reassesses your portfolio and alerts you—before supply chains seize.

• Element-Level Origin Tracking
• 12-Element Validation
• De Minimis Calculation
• End-Use Documentation
• Regulatory Change Alerts

Features Tabs

Declaration Collection

Certivo's automated campaigns achieve 95% response rates vs. 20-30% with manual outreach.

• Targeted campaigns by product line, rare earth element, or supplier geography
• Multi-language outreach including Mandarin, Japanese, Korean, and German
• Intelligent follow-up sequences adapting to supplier behavior
• Format-agnostic: PDFs, Excel, IMDS exports, proprietary templates, freeform responses

Origin Extraction

Every declaration parsed to element and origin level automatically—no manual data entry.

• Deep extraction of rare earth element names, origin countries, content percentages, and alloy compositions
• Parses IMDS exports, IPC-1752 declarations, and proprietary supplier formats
• Multi-language document processing including Chinese-language declarations
• Anomaly detection for inconsistent or suspicious origin claims

Regulatory Monitoring

Always validated against the current controlled list—not your last assessment.

• Automatic sync with MOFCOM announcements and controlled element updates
• De minimis threshold calculations per MOFCOM's 0.1% value guidance
• Proactive alerts when new elements or products are added to controlled lists
• Historical tracking of regulatory changes and suspension periods

Customer Response

Generate rare earth compliance packages in hours instead of 4-6 weeks.

• One-click origin attestation packages with full element-level disclosure
• End-use documentation templates meeting MOFCOM submission requirements
• Supplier declaration chain with complete traceability per component
• Response tracking for license application and customer request deadlines

Export License Support

Pre-validated documentation turns MOFCOM license applications from burden to streamlined workflow.

• Pre-formatted end-use certificates compatible with MOFCOM submission requirements
• Element-level origin mapping for each controlled rare earth in your products
• Automated screening against military end-use and restricted entity indicators
• Compliance notice generation for downstream transfer documentation

Related Regulations

US EAR / BIS Affiliates Rule

US-China export control reciprocity; parallel 50% ownership provisions

EU Critical Raw Materials Act

EU supply chain due diligence for strategic materials including rare earths

ITAR

Defense articles containing rare earth magnets may trigger both regimes

Conflict Minerals (3TG)

Overlapping supply chain transparency and origin tracing requirements

UFLPA

Forced labor due diligence may intersect with rare earth mining operations

REACH (SVHC)

Some rare earth compounds appear on substance restriction lists

Managing rare earth export controls alongside related trade and materials regulations eliminates duplicate supplier requests. Certivo validates one submission against multiple frameworks.

Industries Most Impacted

Electronics Manufacturing

Your Pain Point: NdFeB magnets in motors, speakers, hard drives; Chinese-origin content pervasive

Automotive Manufacturing

Your Pain Point: EV motors require dysprosium-enhanced magnets; OEM flowdown requirements

Industrial & Heavy Equipment

Your Pain Point: Permanent magnets in industrial motors, actuators, sensors across global supply chains

Aerospace & Defense

Your Pain Point: Military end-use prohibition applies; samarium-cobalt magnets critical for guidance systems

Medical Devices & Equipment

Your Pain Point: Gadolinium in MRI contrast; rare earth magnets in imaging and surgical equipment

Energy & Infrastructure

Your Pain Point: Wind turbine generators require tonnes of NdFeB magnets per unit; solar inverters

Semiconductor & High-Tech

Your Pain Point: Europium in display phosphors; erbium in fiber optics; sputtering targets

Construction Materials

Your Pain Point: Rare earth additives in specialty glass, ceramics, and polishing compounds

Return on Investment

80% Reduction in Compliance Labor
From Manual Origin Tracking to Automated Validation
CORA extracts rare earth element data and origin information automatically. Your team focuses on licensing strategy and supply chain decisions—not chasing supplier declarations.

4 hours To Customer Response
Rare Earth Compliance Documentation Acceleration
Generate complete, audit-ready origin attestation and end-use packages in hours—not the months of manual compilation across supplier tiers.

Real-Time Regulatory Change Alerts
Proactive Rare Earth Compliance Monitoring
When MOFCOM announces new controlled elements or modifies licensing requirements, Certivo reassesses your portfolio instantly. Know which products are affected before supply chains are disrupted.

Key Statistics

12 Controlled rare earth elements tracked with automatic MOFCOM sync
99.2% Origin data extraction accuracy from supplier declarations
95% Supplier response rate with CORA-powered campaigns

Frequently Asked Questions

Which rare earth elements are currently subject to China's export licensing requirements?

Seven medium and heavy rare earth elements require MOFCOM export licenses under Announcement 18 (April 2025): samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium—along with all their oxides, alloys, compounds, mixtures, and derivative products including permanent magnets. Five additional elements were announced in October 2025 but suspended until November 2026. Certivo tracks all controlled elements and validates your product portfolio against the current MOFCOM list.

What are the penalties for non-compliance with China's rare earth export controls?

Non-compliance can result in seizure of shipments at Chinese customs, denial of future export license applications, and inclusion on MOFCOM's Control or Watch Lists. Entities placed on control lists face presumptive denial for all future controlled exports. For downstream buyers, receiving unlicensed controlled materials risks supply chain disruption and potential liability under both Chinese and importing-country regulations.

How does the 0.1% de minimis threshold work for products made outside China?

Under the extraterritorial provisions (currently suspended until November 2026), foreign-made products containing Chinese-origin rare earth materials at or above 0.1% by value require a MOFCOM license before export to any third country. This applies to permanent magnets, sputtering targets, and parts or assemblies containing them. CORA calculates de minimis exposure at the product level using supplier-provided origin data across your entire BOM.

How does Certivo help companies prepare for potential reinstatement of the October 2025 controls?

Certivo collects element-level origin data from suppliers now—while the October provisions are suspended. CORA maps Chinese-origin rare earth content across your product portfolio, calculates de minimis thresholds, and identifies products that would trigger extraterritorial licensing obligations if reinstated. This gives your team a compliance-ready posture before November 2026.

How do China's rare earth export controls interact with US export control regulations?

China's 50% Affiliates Rule mirrors the US BIS Affiliates Rule. Products may simultaneously trigger Chinese export licensing (for Chinese-origin rare earth content) and US EAR controls (for US-origin technology content). Certivo validates supplier evidence against both Chinese and US frameworks from a single submission, preventing duplicate campaigns and ensuring dual-jurisdiction compliance.