China: Ban on rare earth-related technologies suspended
In October, China imposed export controls on rare earth-related technologies in October 2025. The decision was published in the Ministry of Commerce Announcement No. 62 of 2025.
In accordance with this Announcement, the following items were not allowed to be exported without a license:
(i) Technologies and carriers related to rare earth mining, smelting and separation, metal smelting, magnetic material manufacturing, and recycling of rare earth secondary resources; (Control Code: 1E902.a)
(ii) Technologies for the assembly, commissioning, maintenance, repair, and upgrading of production lines related to rare earth mining, smelting and separation, metal smelting, magnetic material manufacturing, and rare earth secondary resource recycling. (Control Code: 1E902.b)
The Announcement 62 contained the following provisions:
Exporters must apply for a dual-use export license from the Ministry of Commerce before exporting any non-controlled goods, technologies, or services if they know these items will be used in foreign rare-earth mining, smelting, separation, metal smelting, magnetic-material production, or recycling of secondary rare-earth resources. Export without a license is prohibited. Definitions of the rare-earth-related terms follow the Regulations on the Administration of Rare Earths, and “magnetic material manufacturing technology” specifically covers samarium-cobalt, neodymium-iron-boron, and cerium magnet technologies. Covered technology includes design data, process documents, parameters, and simulations.
The term “export operators” includes all Chinese and foreign individuals or organizations within China, and “export” covers any transfer of the listed items from China to abroad or provision to foreign parties—including through licensing, investment, research, employment, consulting, or similar activities.
Exporters must apply for export licenses as required, and submit the appropriate technology-transfer statements when exporting or providing controlled technology either overseas or to foreign persons inside China. They must also comply with license-use and reporting obligations.
Exporters should maintain strong compliance practices, understand the performance and end-use of their items, and consult the Ministry of Commerce if uncertain whether the announcement applies.
No organization or individual may provide intermediary, logistics, financial, or platform services for activities that violate this announcement. Service providers must check whether exporters’ activities fall under these rules and whether licenses have been obtained.
Technologies already public, used in basic scientific research, or required for standard patent filings are exempt. Unauthorized disclosure of non-public controlled technology after the effective date will be penalized.
Chinese individuals and organizations may not, without approval, offer substantive assistance to overseas rare-earth mining, smelting, magnetic-material production, or recycling activities. Violations will be punished under relevant export-control laws and regulations.
However, the above described export controls were recently suspended.
On the 7 November, the Announcement No. 70 of 2025 was published, announcing the suspension of the implementation of Announcements No. 55, 56, 57, and 58 of 2025 and Announcements No. 61 and 62 of 2025 issued by the Ministry of Commerce and the General Administration of Customs. This means that, for an indefinite time, the export controls on rare earth-related technologies were suspended.
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