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ARTICLE · 15 OCTOBER 2025

PRC Announces New Export Controls On Rare Earth And Battery Materials And Technology

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On October 9, 2025, China's Ministry of Commerce ("MOFCOM") announced in six proclamations broad new unilateral export controls on rare earth materials, equipment, and technology; lithium batteries; and superhard materials.

GlobalInternational Law
Aiysha Hussain
Aiysha Hussain
Timothy J. Keeler
Timothy J. Keeler
Thea Kendler
Thea Kendler
Tamer A. Soliman
Tamer A. Soliman
Howard W. Waltzman
Howard W. Waltzman
Jing Zhang
Jing Zhang
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On October 9, 2025, China's Ministry of Commerce ("MOFCOM") announced in six proclamations broad new unilateral export controls on rare earth materials, equipment, and technology; lithium batteries; and superhard materials. For certain items, these measures extend People's Republic of China (PRC) jurisdiction extraterritorially to items produced outside of China with controlled PRC technology or materials.

These new measures were couched by a MOFCOM spokesman as responsive to both diversion risks and the September 29 US export control expansions affecting affiliates and subsidiaries of listed parties. Although their regulatory terms are similar to those of the US de minimis-and foreign direct product rule (FDPR)-based export controls, China's new controls corral a wide swath of commercial items without reference to their national security applications.

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