Trade & Customs
Rare earth elements subject to MOFCOM export licensing
De minimis value threshold triggering extraterritorial controls
MOFCOM export license review period
Regulation Overview
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
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
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.
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 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.
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
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
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.
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.
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
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.