由 caicai8478 In recent years, China’s export control policy on sensitive goods has become increasingly stringent, especially in the field of dual-use items and strategic minerals. These policies are not only related to national security, but also have a profound impact on the global supply chain and geopolitical landscape. The following is an in-depth analysis of China’s recent export control policy on sensitive goods:
- New regulations on export control of dual-use items: Optimization of customs challenge procedures
On June 16, 2025, the General Administration of Customs issued the “Announcement on Customs Challenges on Export Control of Dual-Use Items” (Announcement No. 123 of the General Administration of Customs in 2025), further standardizing the export control process of dual-use items1610. The main contents include:
Question initiation conditions: When the customs finds that the exported goods may fall within the scope of control but no license has been submitted, it can initiate the challenge procedure and issue a “Question Notice”.
Enterprise obligations: The enterprise must submit materials such as customs declarations, contracts, technical specifications, test reports, etc. within 7 working days to prove that the goods do not fall within the scope of control1.
Disposal rules:
If no license is required, the goods can be released;
If a license is required, the goods will not be released;
If it cannot be determined, the customs will apply to the national export control management department for identification6.
Goods status management: During the period of questioning or identification, the goods will not be released to prevent the illegal outflow of sensitive items10.
This policy strengthens the customs supervision capacity and clarifies the compliance responsibilities of enterprises, which helps to balance trade facilitation and national security.
- Rare earth export control: civilian release, military ban
China’s export control of rare earth elements has become a global focus, especially the control of seven types of medium and heavy rare earths such as samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium in April 2025259:
Strategic significance:
These rare earth elements are key materials for stealth fighter coatings, missile guidance systems, and nuclear submarine propulsion motors2.
China controls 90% of the world’s refining capacity and 99% of the heavy rare earth supply, making it a dominant player in the supply chain2.
Dual-track strategy:
Civilian sectors (such as automobiles and new energy) can apply for temporary licenses. For example, in June 2025, the three major US automakers (GM, Ford, and Stellaris) were granted a 6-month rare earth export license2.
Military sectors are strictly prohibited, and US military companies (such as Lockheed Martin) cannot obtain rare earth supplies2.
Global impact:
The price of medium and heavy rare earths in the European market has soared to 2-3 times the pre-control level8.
Automakers in the United States, Japan, India and other countries are facing the risk of suspension of production due to limited supply of rare earth magnets9.
This policy not only maintains national security, but also affects the global industrial chain through precise regulation, weakening the technological advantages of the Western military-industrial complex25.
- Other strategic mineral controls: semiconductors and key new energy materials
In addition to rare earths, China also implements export controls on a variety of strategic minerals:
December 2024: Gallium, germanium, antimony, superhard materials, and graphite are prohibited from being exported to the United States for military purposes3.
February 2025: 25 new rare metals, including tungsten, tellurium, bismuth, molybdenum, and indium, will be added to the control3.
April 2025: Strengthen the control of medium and heavy rare earths, covering metallurgy, aerospace, military industry and other fields39.
These measures are aimed at preventing key materials from being used for military or high-tech competition, while promoting domestic industrial upgrading.
- Policy logic and global game
National security first: China prevents sensitive technologies from being used for military purposes through export controls, such as the US F-47 sixth-generation aircraft project facing delays due to rare earth supply cuts2.
Supply chain control: China uses its monopoly on rare earths and key minerals to shape global trade rules and weaken Western efforts to rebuild supply chains3.
Countering US technology blockade: In the Sino-US technology war, China responded to the US chip ban with rare earth and semiconductor material controls47.
- Corporate compliance challenges and responses
Export companies need to strengthen compliance management to ensure that the export of sensitive items meets license requirements1.
Supply chain diversification: Some countries (such as the United States and the European Union) are accelerating the development of rare earth mining and recycling technologies to reduce their dependence on China59.
Legal risks: False declaration of product names, smuggling by customs, etc. may constitute smuggling crimes, facing high fines or even criminal liability3.
Conclusion
China’s sensitive commodity export control policy reflects the dual goals of “national security + industrial competition”. By accurately regulating the export of key materials, it not only safeguards its own interests, but also affects the global science and technology and military landscape. In the future, as the Sino-US game intensifies, relevant control measures may be further refined. Enterprises need to pay close attention to policy trends and optimize the compliance system to meet challenges.