December 2025
An Overview of China’s Rare Earth Export Control Policies (Mainland China)
With the rapid growth of high-tech industries and artificial intelligence, countries around the world have paid close attention to the security of rare earth supply chains. Rare earths are critical materials. In 2025, China introduced several export control measures targeting rare earths. These measures cover raw materials, alloys, equipment, and key technologies. For the first time, China also applied extra-territorial jurisdiction to products made outside China and exported to third countries if those products contain a certain percentage of rare earth elements.
Rare earths refer to 17 chemical elements, including scandium, yttrium, and the lanthanides. Based on their physical and chemical properties, people usually divide them into light rare earths and heavy rare earths [1] . Many people call rare earths “industrial vitamins.” Manufacturers widely use them in electric vehicles, wind turbines, semiconductors, and military and defense products [2] . China holds a dominant position in the global rare earth supply chain. It produces more than 60% of the world’s rare earth minerals and controls over 90% of global processing capacity. As a result, China’s rare earth policies strongly affect manufacturing processes and international trade in high-tech industries [3] .
On April 4, 2025, the Ministry of Commerce of China issued Announcement No. 18 of 2025. This announcement applies export controls to seven rare earth elements—samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium—and related materials (collectively, the “Announcement No. 18 Control Elements”). When exported items contain the Announcement No. 18 Control Elements, exporters must, pursuant to the Foreign Trade Law of the People’s Republic of China and the Customs Law of the People’s Republic of China, and the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, apply for prior approval.
Later, on October 9, 2025, the Ministry of Commerce of China issued several additional announcements to expand export controls. The key measures are summarized as follows:
I. Inclusion of Rare Earth Equipment and Raw and Auxiliary Materials
Under Announcement No. 56 of 2025 of The Ministry of Commerce, export operators must apply for licenses before exporting rare earth production and processing equipment. Such equipment includes centrifugal extraction equipment, resistance furnaces, and electrolytic cells. The same rule applies to raw and auxiliary materials, such as rare earth ores and extraction agents.
II. Expansion of Controlled Rare Earth Elements
Announcement No. 57 of 2025 of The Ministry of Commerce added five more rare earth elements—europium, holmium, erbium, thulium, and ytterbium—to the control list (the “Announcement No. 57 Control Elements”). As of now, China has applied export controls to 12 of the 17 rare earth elements. Exporters must apply for approval if their products contain any of the Announcement No. 18 Control Elements or Announcement No. 57 Control Elements.
III. Extra-Territorial Jurisdiction Framework
Announcement No. 61 of 2025 of The Ministry of Commerce provides that, when organizations and individuals outside China export the following items to countries or regions outside China, they must obtain a dual-use item export license issued by the competent authority in advance:
(1) Items that contain rare earth elements of Chinese origin—samarium, dysprosium, gadolinium, terbium, lutetium, scandium, yttrium—as well as samarium–cobalt alloys, terbium–iron alloys, dysprosium–iron alloys, terbium–dysprosium–iron alloys, dysprosium oxide, and terbium oxide (collectively, the “Announcement No. 61 Control Elements”), where such components account for 0.1% or more of the value of the item;
(2) Items related to the Announcement No. 61 Control Elements that are produced using technologies from China’s industrial supply chain; and
(3) Items related to the Announcement No. 61 Control Elements that are of Chinese origin.
IV. Prohibition on Exports to Certain Entities
Under Announcement No. 61 of 2025 of The Ministry of Commerce, the competent authority will generally deny export applications involving overseas military end users. The same rule applies to importers and users listed on the Export Control List or the watch list, including their subsidiaries and branches.
V. Prohibition on Exports for Military Use
Announcement No. 61 of 2025 of The Ministry of Commerce also provides that, if an export application involves military use or may enhance military capabilities, the competent authority will generally deny the application.
VI. Restrictions on Semiconductor and AI-Related Exports
Announcement No. 61 of 2025 of The Ministry of Commerce further restricts exports related to advanced semiconductor and AI technologies. The authority will review applications case by case if the final use involves logic chips at 14 nanometers or below and memory chips with 256 layers or more. The same applies to equipment, testing tools, materials for these processes, or artificial intelligence research with potential military use.
VII. Control of Key Rare Earth Technologies
Under Announcement No. 62 of 2025 of The Ministry of Commerce, exporters must apply for approval before exporting key rare earth technologies. These technologies include rare earth mining, smelting and separation, metal smelting, manufacturing of magnetic materials, and recycling and use of secondary rare earth resources.
Rare earths play a key role in producing advanced chips and permanent magnets. These strict control measures may significantly affect the chip manufacturing market. They also increase uncertainty for the semiconductor and artificial intelligence industries. Following the U.S.–China talks on October 30, 2025, trade tensions eased. On November 7, 2025, the Ministry of Commerce of China issued Announcement No. 70 of 2025 of The Ministry of Commerce. This announcement suspended all measures issued on October 9, 2025, until November 10, 2026. As a result, global concerns over chip supply chains were temporarily alleviated.
Since 2025, China has continued to introduce rare earth control measures based on its strong position in the global supply chain. Although many measures are currently suspended, Announcement No. 18 of 2025 of The Ministry of Commerce has been in effect since April 4, 2025. Its impact is significant. For example, AI robot motors rely on NdFeB magnets. These magnets require neodymium, praseodymium, dysprosium, and terbium to maintain heat resistance and stability [4] . Therefore, Announcement No. 18 of 2025 of The Ministry of Commerce continues to affect AI robotics and other downstream industries that rely on such magnets.
We advise relevant companies to evaluate supply chain risks and the sources of raw materials early, and we will continue to monitor developments in export control policies and licensing review mechanisms.
Rare earths refer to 17 chemical elements, including scandium, yttrium, and the lanthanides. Based on their physical and chemical properties, people usually divide them into light rare earths and heavy rare earths [1] . Many people call rare earths “industrial vitamins.” Manufacturers widely use them in electric vehicles, wind turbines, semiconductors, and military and defense products [2] . China holds a dominant position in the global rare earth supply chain. It produces more than 60% of the world’s rare earth minerals and controls over 90% of global processing capacity. As a result, China’s rare earth policies strongly affect manufacturing processes and international trade in high-tech industries [3] .
On April 4, 2025, the Ministry of Commerce of China issued Announcement No. 18 of 2025. This announcement applies export controls to seven rare earth elements—samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium—and related materials (collectively, the “Announcement No. 18 Control Elements”). When exported items contain the Announcement No. 18 Control Elements, exporters must, pursuant to the Foreign Trade Law of the People’s Republic of China and the Customs Law of the People’s Republic of China, and the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, apply for prior approval.
Later, on October 9, 2025, the Ministry of Commerce of China issued several additional announcements to expand export controls. The key measures are summarized as follows:
I. Inclusion of Rare Earth Equipment and Raw and Auxiliary Materials
Under Announcement No. 56 of 2025 of The Ministry of Commerce, export operators must apply for licenses before exporting rare earth production and processing equipment. Such equipment includes centrifugal extraction equipment, resistance furnaces, and electrolytic cells. The same rule applies to raw and auxiliary materials, such as rare earth ores and extraction agents.
II. Expansion of Controlled Rare Earth Elements
Announcement No. 57 of 2025 of The Ministry of Commerce added five more rare earth elements—europium, holmium, erbium, thulium, and ytterbium—to the control list (the “Announcement No. 57 Control Elements”). As of now, China has applied export controls to 12 of the 17 rare earth elements. Exporters must apply for approval if their products contain any of the Announcement No. 18 Control Elements or Announcement No. 57 Control Elements.
III. Extra-Territorial Jurisdiction Framework
Announcement No. 61 of 2025 of The Ministry of Commerce provides that, when organizations and individuals outside China export the following items to countries or regions outside China, they must obtain a dual-use item export license issued by the competent authority in advance:
(1) Items that contain rare earth elements of Chinese origin—samarium, dysprosium, gadolinium, terbium, lutetium, scandium, yttrium—as well as samarium–cobalt alloys, terbium–iron alloys, dysprosium–iron alloys, terbium–dysprosium–iron alloys, dysprosium oxide, and terbium oxide (collectively, the “Announcement No. 61 Control Elements”), where such components account for 0.1% or more of the value of the item;
(2) Items related to the Announcement No. 61 Control Elements that are produced using technologies from China’s industrial supply chain; and
(3) Items related to the Announcement No. 61 Control Elements that are of Chinese origin.
IV. Prohibition on Exports to Certain Entities
Under Announcement No. 61 of 2025 of The Ministry of Commerce, the competent authority will generally deny export applications involving overseas military end users. The same rule applies to importers and users listed on the Export Control List or the watch list, including their subsidiaries and branches.
V. Prohibition on Exports for Military Use
Announcement No. 61 of 2025 of The Ministry of Commerce also provides that, if an export application involves military use or may enhance military capabilities, the competent authority will generally deny the application.
VI. Restrictions on Semiconductor and AI-Related Exports
Announcement No. 61 of 2025 of The Ministry of Commerce further restricts exports related to advanced semiconductor and AI technologies. The authority will review applications case by case if the final use involves logic chips at 14 nanometers or below and memory chips with 256 layers or more. The same applies to equipment, testing tools, materials for these processes, or artificial intelligence research with potential military use.
VII. Control of Key Rare Earth Technologies
Under Announcement No. 62 of 2025 of The Ministry of Commerce, exporters must apply for approval before exporting key rare earth technologies. These technologies include rare earth mining, smelting and separation, metal smelting, manufacturing of magnetic materials, and recycling and use of secondary rare earth resources.
Rare earths play a key role in producing advanced chips and permanent magnets. These strict control measures may significantly affect the chip manufacturing market. They also increase uncertainty for the semiconductor and artificial intelligence industries. Following the U.S.–China talks on October 30, 2025, trade tensions eased. On November 7, 2025, the Ministry of Commerce of China issued Announcement No. 70 of 2025 of The Ministry of Commerce. This announcement suspended all measures issued on October 9, 2025, until November 10, 2026. As a result, global concerns over chip supply chains were temporarily alleviated.
Since 2025, China has continued to introduce rare earth control measures based on its strong position in the global supply chain. Although many measures are currently suspended, Announcement No. 18 of 2025 of The Ministry of Commerce has been in effect since April 4, 2025. Its impact is significant. For example, AI robot motors rely on NdFeB magnets. These magnets require neodymium, praseodymium, dysprosium, and terbium to maintain heat resistance and stability [4] . Therefore, Announcement No. 18 of 2025 of The Ministry of Commerce continues to affect AI robotics and other downstream industries that rely on such magnets.
We advise relevant companies to evaluate supply chain risks and the sources of raw materials early, and we will continue to monitor developments in export control policies and licensing review mechanisms.
[1]
Chang, C. (2019, December 11). Examining the Impact of Rare Earths on Taiwan’s Industries through Materials Used in Mobile Phones. Department of Industrial Technology, MOEA. https://www.moea.gov.tw/Mns/doit/industrytech/IndustryTech.aspx?menu_id=13545&it_id=272
Light rare earths include lanthanum (La), cerium (Ce), praseodymium (Pr), neodymium (Nd), promethium (Pm), samarium (Sm), europium (Eu), and gadolinium (Gd).
Heavy rare earths include terbium (Tb), dysprosium (Dy), holmium (Ho), erbium (Er), thulium (Tm), ytterbium (Yb), lutetium (Lu), scandium (Sc), and yttrium (Y).
[2]
Ibid.
[3]
Maruf, R. (2025, October 11). What Are Rare Earth Minerals, and Why Are They Central to Trump’s Threats Against China? CNN. https://edition.cnn.com/2025/10/11/business/rare-earth-minerals-trump-china-xi
[4]
The Invisible Constraint on the Development of AI Robots: Dependence on Rare Earths and Geopolitical Risks. (2025, September 16). United Daily News. https://udn.com/news/story/6871/9008492
