China expands export controls on rare earths

On April 4, 2025 China first introduced export controls on seven rare earths: samarium, scandium, dysprosium, terbium, gadolinium, lutetium and yttrium. Since then, foreign companies importing these raw materials from China have been required to apply for permits from the Chinese Ministry of Commerce (MOFCOM). This also applies to their alloys, mixtures, and permanent magnets.

Expansion of export controls

On October 9, 2025 MOFCOM published Declaration 61 and Declaration 62 which significantly expanded these Chinese export controls:

• Additional rare earths: Since October 9, 2025 holmium, erbium, thulium, europium and ytterbiu are subject to Chinese export controls. Foreign companies need permits if they want to import these rare earths from China.
• Technologies: Since October 9, 2025 Chinese companies need permits for exporting technologies for mining, smelting and separating as well as recycling rare earths. The same is true for technologies for metal smelting and the production of magnets. Permits are also required for technologies for the commissioning, maintenance, and repair of production equipment. Export here refers not only to the delivery of controlled technology from China to a foreign country, but also to its transfer within China to foreign individuals or organizations.
• Goods manufactured abroad: From December 1, 2025, foreign companies will require approval from MOFCOM if they resell the following goods to other countries and regions (except China): (1) Goods manufactured abroad that contain 0.1 percent of the 12 controlled rare earths from China. (2) Goods produced abroad using Chinese technologies related to the mining, smelting, and separation of rare earths, metal smelting, magnet production, or rare earth recycling. In addition, foreign companies must issue a Compliance Notice to the recipient of these goods in accordance with the Compliance Guidelines of Proclamation No. 61.
• General ban on approval: Export applications that are used or expected to be used for the following end uses will generally not be approved as of October 9, 2025:

  • Design, development, production, and use of weapons of mass destruction and their delivery systems
  • Terrorist purposes
  • Military use or enhancement of military potential.
• Semiconductors: Export applications for the production of certain semiconductors or the development of artificial intelligence with a potential military end use require a case-by-case assessment as of October 9, 2025.
• Technical assistance: As of October 9, 2025, Chinese citizens, legal entities, and organizations require a permit to support activities abroad related to the mining, smelting, and separation of rare earths, metal smelting, magnet manufacturing, or rare earth recycling.