As part of its implementation of a bilateral trade agreement reached with the U.S. last month, China has taken the following steps to suspend multiple export control measures and remove U.S. entities from restricted lists.
Rare earths. Effective Nov. 7, China suspended until Nov. 10, 2026, its implementation of export controls announced on Oct. 9, 2025, with respect to superhard materials, rare earth equipment and certain raw materials (holmium, erbium, thulium, europium, and ytterbium), medium and heavy rare earths, lithium batteries, artificial graphite anode materials, and related rare earth items and technologies.
De minimis rule. China has suspended enforcement of a rule that would have required a Chinese export license for any transfer or resale of certain foreign-made products containing 0.1 percent or more of any China-origin controlled rare earth element even if the product was manufactured abroad. Enforcement had been slated to begin Dec. 1, 2025.
Dual-use goods. Effective Nov. 9, 2025, and continuing until Nov. 27, 2026, dual-use items incorporating gallium, germanium, antimony, superhard materials, and graphite may be exported to the U.S. provided a valid export license is obtained. China had previously stipulated that graphite dual-use items would be subject to stricter end-use and end-user reviews and that export licenses for dual-use items made with the other materials and destined for the U.S. would generally not be granted.
Control lists. China has removed 21 U.S. entities from its unreliable entity list and 31 U.S. entities from its export control lists. As a result, Chinese companies are now permitted to engage in transactions with these entities and previously imposed restrictions have been lifted or suspended.
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