Since August 2023, China has progressively expanded export controls over strategic materials — beginning with gallium and germanium and extending through graphite, antimony, tungsten, and the medium and heavy rare earths that include scandium. This reference lays out the controls that remain in force as of June 2026 in a single timeline, then summarizes the current status of each item and what it means for sourcing. The key point: most of these measures are not embargoes but case-by-case licensing regimes, and the odds of obtaining a license — along with the availability of alternative supply — differ item by item.
Why a Timeline Matters
China's export controls do not arrive as a single announcement. They accumulate: new items are added, extraterritorial reach is tightened, and portions are later suspended under bilateral agreements. For a procurement team, that means the questions "Is our material controlled right now?", "Can it be cleared with a license?", and "How long does this status hold?" have to be re-answered at each point in time. Because the control list is updated through Ministry of Commerce (MOFCOM) announcements and negotiated agreements, verifying the latest status must precede any sourcing contract design.
Export Control Timeline (2023–2026)
The relationship between October and November 2025 deserves particular attention. In October 2025, five items were added and extraterritorial reach was strengthened (applying controls to foreign-made goods above a threshold of Chinese content). Under the November 2025 US–China agreement, only the October additions were suspended, for one year to 10 November 2026 unless the suspension is extended. Anyone designing a contract that runs past that date should treat the October items as controlled until an extension is confirmed. The seven items controlled under the April 2025 Announcement No. 18 — scandium among them — were not part of that suspension and remain fully in force as of June 2026.
Per-Item Status Summary
Scandium and medium/heavy rare earths (Apr 2025, Announcement No. 18)
All forms of the seven controlled items — metals, alloys, oxides, compounds, and mixtures — are subject to control, with no concentration-floor threshold, and each shipment requires a case-by-case MOFCOM license. MOFCOM's stated policy is denial for military end use. Dual-use applications with a plausible military pathway draw the heaviest scrutiny, while clearly civilian uses are selectively approved on the strength of end-user and end-use documentation. Scandium oxide (Sc₂O₃) prices roughly tripled across the control threshold: pricing data from lanthanides.io puts Sc₂O₃ at about $1,200/kg before the controls and $3,500–4,370/kg after, without a stated grade or purity basis. The multiple is the durable signal rather than the absolute levels — this is a market thin enough that a handful of transactions set the print, and export prices diverged from Chinese domestic levels after the controls took effect. The detailed impact is covered in Scandium Export Controls and the SOFC Supply Chain and Scandium: A Rare Metal Produced at Only ~40 Tonnes a Year.
Tungsten (Feb 2025)
Tungsten and four other items were added to the control list in February 2025 and remain in force as of June 2026. This group affects cemented-carbide and tool-steel supply chains.
Antimony and superhard materials (2024)
Antimony and superhard materials such as synthetic diamond were brought under control in 2024, touching abrasive, cutting, and flame-retardant supply chains.
Gallium, germanium, graphite (2023)
The earliest controlled group spans compound semiconductors (gallium), optics and optical fiber (germanium), and battery anode material (graphite). All remain in force as of June 2026.
Example of an uncontrolled item: silicon carbide (SiC)
Abrasive- and metallurgical-grade silicon carbide powder (HS 2849.20) is not subject to Chinese export controls as of June 2026, and Korea imposes no import restrictions (such as anti-dumping) on it. The higher-value forms are a separate question: SiC fibers, whiskers, and continuous filament for ceramic-matrix composites appear on dual-use control lists, and semiconductor-grade substrate material is an active policy target. So the blanket assumption that "all ceramics are fine" is risky; each item should be verified at the level of its HS code and specification. That specification has to name the grade band — metallurgical and refractory through black abrasive and high-purity ceramic to crystal-growth 4N+ — and then say how the iron limit is read, because a bare Fe₂O₃ figure hides whether iron was measured as the element or as the oxide. Our green SiC micro powder page sets that out in its verification list: iron reported as the element, with the Fe₂O₃ conversion shown. The structure and price tiers of the SiC market are laid out in 2026 Global SiC Market Outlook.
A Three-Step Sourcing Check
The basic sequence for managing sourcing risk under export controls is:
- Confirm whether the item is controlled. Check your raw materials, intermediates, and finished goods against the latest control list at the level of HS code and specification. Even when a finished product is not controlled, its input (for example, the scandium inside a finished ScSZ product) may be.
- Design the license track. If the item is controlled, prepare civilian end-use documentation. MOFCOM reviews applications per contract, filed by the Chinese exporter, and there is no published size-based queue — but the observed early pattern is that an exporter with limited licensing bandwidth spends it on its largest customers first, which leaves small spot orders the most exposed.
- Run a non-China alternative in parallel. To hedge against license delays or refusals, secure supply outside China as well — noting that those jurisdictions run export-control regimes of their own, so the item still has to be classified on that side. The concrete strategy is detailed in Procurement Strategy in the Export-Control Era.
Frequently Asked Questions
Does a Chinese export control mean an outright import ban?
No. Most of the listed measures are case-by-case licensing regimes, not embargoes. Shipments can be approved when a civilian end use is documented; MOFCOM's stated policy is denial for military end use, and dual-use applications with a plausible military pathway draw the heaviest scrutiny. That said, license review takes time and small orders can be deprioritized, so lead times and contract terms should account for it.
Did the November 2025 suspension release scandium too?
No. The November 2025 agreement suspended only the October 2025 additions, for one year to 10 November 2026 unless extended. The April 2025 Announcement No. 18, which includes scandium, was not part of the suspension and remains fully in force as of June 2026.
How do we confirm whether an item we use is controlled?
Start by cross-checking the item's HS code and chemical specification against the latest MOFCOM announcements. Verify the finished product and its inputs separately, and when the determination is difficult, have it reviewed by a customs or export-control specialist.
Will the control list keep changing?
Very likely. Since 2023 the pattern has been repeated additions and partial suspensions, so when designing a sourcing contract you should re-verify the status as of the contract date and build in protective clauses such as a deadline-triggered right to terminate if an export license has not issued.
References (Public Sources)
- China Ministry of Commerce (MOFCOM) Announcement No. 18 (Apr 2025)
- Holland & Knight, legal analysis of China export controls (Apr 2025)
- Pillsbury, analysis of the US–China agreement and suspension (Nov 2025)
- lanthanides.io, scandium oxide price trends
Because this list is re-answered at each announcement rather than settled once, sourcing has to be designed around the licence step instead of around a hoped-for exemption. Nami Tech Solutions (NTS) approaches mills directly, in their own language and against the same written specification, and settles classification, origin documents, Incoterms and payment structure in the contract, from sixteen years of trade practice.
