China Hits “Pause” on Rare-Earth Export Controls and What it Means for Supply Chains

China’s decision to pause several newly announced rare-earth and critical-mineral export controls marks a significant, although temporary, shift in the global supply-chain landscape. Through the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) Announcements No. 70 and No. 72 (2025), Beijing has suspended both the October rare-earth restrictions and the U.S.-specific dual-use licensing requirements that were set to tighten dramatically in 2025–2026. While framed as a confidence-building step following recent U.S.– China diplomatic engagement, the suspension offers industries dependent on rare earths, advanced magnets, and battery materials a brief window to reassess sourcing strategies, secure licensing where available, and prepare for the likelihood that controls may return once broader geopolitical calculations evolve.

On Nov. 7, MOFCOM issued Announcement No. 70, suspending implementation of six October directives (Announcements 55–58, 61, and 62) that would have significantly tightened export licensing requirements for rare-earth elements, magnet materials, lithium-battery inputs, and super-hard materials.

Two days later, on Nov. 9, MOFCOM Announcement No. 72 went further by suspending Article 2 of Announcement No. 46 (2024) until Nov. 27, 2026. This effectively pauses enhanced U.S.-focused licensing requirements for dual-use items such as gallium, germanium, antimony, graphite, and super-hard materials, restoring exports of these materials to China’s standard licensing framework.

Together, these actions amount to a measured de-escalation of trade pressure on U.S.-bound shipments, even as both governments continue recalibrating the strategic balance between technological control and supply-chain stability.

Context: A Tactical Pause Amid Strategic Rivalry

The suspensions follow late-October discussions between Presidents Donald Trump and Xi Jinping in the Republic of Korea. The U.S. reportedly agreed to delay implementation of the “Affiliates Rule” under the Export Administration Regulations (“EAR”), which would have extended U.S. export-control jurisdiction to foreign subsidiaries 50 percent owned by Entity List parties.

In parallel, China agreed to pause global implementation of the October 9 rare-earth and critical-mineral controls. Both sides framed these steps as temporary, confidence-building measures designed to stabilize bilateral economic conditions while preserving each country’s long-term leverage.

As in the past, Beijing’s moves are tactical rather than ideological, reflecting a pragmatic calculation that easing commercial strain can buy diplomatic space without surrendering regulatory authority. From a strategic perspective, the suspensions reflect a pause in escalation, not a retraction of China’s broader policy objective to consolidate control over global rare-earth and advanced-materials supply chains.

What Has Been Suspended

China’s recent announcements amount to a broad, coordinated pause on a suite of export-control measures that, taken together, would have reshaped global access to rare earths and other strategic minerals. Through Announcement No. 70, Beijing temporarily shelved six separate directives issued on October 9, measures that would have imposed new licensing requirements on rare-earth elements, magnet materials, lithium-battery precursors, and a range of super-hard industrial materials. Particularly significant among these was Announcement 61, which introduced an extraterritorial licensing obligation for foreign-made products incorporating Chinese-origin rare-earth materials or technologies. That requirement has now been put fully on hold, along with planned restrictions on the export of rare-earth processing technologies and know-how.

In addition, Announcement 72 suspends the portion of Announcement 46 that would have imposed new U.S. specific licensing requirements, including restrictions on exports of gallium, germanium, antimony, and super-hard-material-related items, as well as enhanced end-use reviews for graphite items. By suspending Article 2, China has paused stricter licensing requirements for certain dual-use items and restored the ability of exporters to seek approvals through ordinary licensing channels.

Taken together, the November 7 and 9 announcements do not dismantle China’s emerging export-control architecture, but they do interrupt its immediate expansion. For exporters and downstream manufacturers, the result is a temporary return to familiar licensing procedures and a moment of regulatory stability in an otherwise fast-tightening environment.

What Remains in Force

Despite the high-profile suspensions, China’s underlying export-control architecture remains largely intact, and in several critical areas, unchanged. The most consequential of these continuing restrictions is Article 1 of Announcement 46 (2024), which still categorically prohibits exports of dual-use items to U.S. military end users or for military end-use applications. None of the November announcements altered or narrowed this prohibition, meaning that China’s military-end-use firewall remains firmly in place.

Equally important is the fact that China’s earlier expansion of its Dual-Use Items Control List continues to apply without interruption. Announcement 18 (2025), which added seven medium- and heavy-rare-earth elements, including samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium, along with their metals, oxides, alloys, compounds, mixtures, and magnet materials, has not been suspended. These additions now sit permanently within the framework governing controlled materials and continue to trigger licensing obligations for both Chinese exporters and foreign purchasers. Earlier controls on tungsten, tellurium, bismuth, molybdenum, indium, and other strategic minerals issued in 2025 also remain intact. Companies handling these materials must continue evaluating whether their products meet the technical thresholds set out in the Dual-Use Items Control List and whether ongoing licensing requirements apply.

Viewed in their full context, these continuing obligations make clear that Beijing’s recent steps amount to a pause in escalation, not a strategic reversal. Although the October measures have been placed on hold, China’s broader and steadily expanding export-control regime remains firmly in place, and compliance, classification, and supply-chain due diligence remain just as essential as before the suspension.

Implications for U.S. Importers and Global Supply Chains

For industries dependent on rare-earths and critical minerals, including EVs, semiconductors, aerospace, magnets, and biomedical coatings, the suspension offers temporary relief but should not be mistaken for deregulation.

• Compliance Planning: Companies should continue mapping Chinese-origin inputs, reviewing supplier declarations, and documenting product classifications under both U.S. and Chinese control lists.
• Licensing Strategy: Exporters and importers should consider applying for general licenses now, while the review environment remains more favorable.
• Contingency Preparation: Expect regulatory tightening in late 2026 if bilateral conditions deteriorate or MOFCOM reinstates suspended announcements.

From a geopolitical perspective, the current détente is symptomatic of strategic interdependence: both Washington and Beijing remain locked in competition for technological primacy yet mutually constrained by the shared necessity of stable supply chains. The suspension, therefore, represents a pause for recalibration, not reconciliation.

Contact Clark Hill

Clark Hill’s International Trade team is closely monitoring MOFCOM’s evolving export-control framework, including the operational impact of the current suspension period. With the window for obtaining general licenses now more favorable, our team can assist companies in evaluating whether their products fall within the Dual-Use Items Control List and in preparing and submitting license applications while the pause remains in place.

If you have questions regarding the content of this alert, please contact any member of Clark Hill’s International Trade Practice:

• Mark Ludwikowski (mludwikowski@clarkhill.com; 202-640-6680)
• Kevin Williams (kwilliams@clarkhill.com; 312-985-5907)
• Kelsey Christensen (kchristensen@clarkhill.com; 202-640-6670)
• Aristeo Lopez (alopez@clarkhill.com; 202-552-2366)
• Laura M. Quesada (Lquesada@clarkhill.com; 202-240-0170)

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