If you buy dysprosium, scandium or yttrium out of China, you have probably been given a deadline. Possibly several, and possibly not the same one twice. November 10, 2026 is the date in the headlines. December 31, 2026 turns up in searches often enough that people are clearly being told it matters. Both dates are real. Neither is necessarily the one that governs the shipment sitting in your schedule.
This is not a case of bad reporting. It is that China licenses exports through two different systems that happen to share a ministry, a customs authority and a name, and only one of them runs on the calendar. Read the wrong clock and you will either panic in December for no reason or miss the expiry that actually applies to you.
The Two Systems, and Why They Get Confused
The ordinary export licence (出口许可证) covers goods on the annual export licensing catalogue — textiles, certain metals, a long list of ordinary trade items. Its administration is explicitly calendar-bound. A licence runs at most six months, and, in the words of the issuing rules, its expiry may not fall later than December 31 of the same year. Issuing offices may start writing next year's licences from December 10, marked as valid from January 1. Extensions granted against that year's quota likewise cannot reach past December 31.
That is a genuine, hard December 31 wall. It is also almost certainly the source of the date circulating in dysprosium searches.
The dual-use export licence (两用物项出口许可) is a different instrument under different law: the Regulations on Export Control of Dual-Use Items, State Council Order No. 792, in force since December 1, 2024. Article 15 sets the validity plainly:
单项许可的有效期不超过1年，有效期内完成出口的，出口许可证件自动失效。
通用许可的有效期不超过3年。
A single licence is valid for up to one year and lapses automatically once the export is completed. A general licence runs up to three years. There is no calendar-year rule anywhere in it. No December 31 ceiling, no year-end reissue cycle.
Dysprosium is controlled under the second system, not the first. So are samarium, gadolinium, terbium, lutetium, scandium and yttrium — the seven medium and heavy rare earths placed under licensing by MOFCOM and the General Administration of Customs in Announcement No. 18 of April 4, 2025, across metal, alloy, target, oxide, compound, mixture and permanent-magnet forms.
The practical consequence is worth stating flatly. Your dual-use licence expires on its own anniversary, not on New Year's Eve. Two shipments licensed three months apart have expiry dates three months apart. There is no shared cliff to plan around, which is inconvenient in a different way: you cannot manage this with one diary entry for the whole programme.
What Actually Happens on December 31, 2026
One thing, and it is not a licence expiring.
Every year MOFCOM and the customs authority publish the following year's Catalogue of Dual-Use Items and Technologies Subject to Import and Export Licensing. The 2026 edition was issued as Announcement No. 91 of 2025, dated December 31, 2025, and took effect January 1, 2026. On that schedule the 2027 edition lands on or about December 31, 2026.
What turns over is the classification layer, not the permission. The catalogue is what maps a controlled item to the customs codes and licence types you declare against. When an edition changes, entries can be added, split, merged or recoded — and a specification that cleared customs in December under one code can require a different declaration in January. Your licence does not expire because of it; your paperwork can nonetheless stop matching.
For a buyer, the year-end question is therefore not "does my licence run out" but "was my licence issued against a catalogue edition that is about to be replaced." Those are different questions with different answers and different remedies.
The Deadline That Is Actually in the Headlines
November 10, 2026 is a real and much larger date, and it belongs to neither of the mechanisms above.
On October 9, 2025 MOFCOM published Announcements No. 61 and No. 62, extending control to rare-earth items produced outside China with Chinese content and to rare-earth technology. Following the US–China talks, implementation of the October 9 measures was suspended for one year, to November 10, 2026. The United States suspended its own BIS affiliates rule on a matching clock.
Two points matter for anyone reading this as a dysprosium buyer.
First, what was suspended is the October 2025 expansion, not the April 2025 regime. Announcement No. 18 has never been suspended. Dysprosium, scandium and yttrium require case-by-case export licences today, and will on November 11, 2026, whatever happens to the suspension. Coverage that treats November 10 as "the day rare earth controls return" is describing the expansion, not the baseline.
Second, a suspension expiring is not the same as a control resuming automatically. It is a decision point. We do not have a defensible prediction about which way it goes and are not offering one.
Reading Your Own Paperwork
Four checks, in the order that resolves the ambiguity fastest.
Which licence type is on the document. Dual-use single licence, dual-use general licence, or ordinary export licence. Only the last is calendar-bound. If nobody in the chain can tell you which one it is, that is your answer about how well the shipment is understood.
The issue date and the stated validity, not an assumed year-end. For a dual-use single licence the ceiling is one year from issue and it lapses on completion of the export. A licence used for a partial shipment does not silently carry a remainder to a new year.
Whether your supplier holds a general licence. A general licence covers repeat exports to named, pre-vetted end users for up to three years, which removes the per-consignment approval step entirely. This is the single largest lead-time variable available to you, and it is a question with a yes or no answer that most buyers never ask.
The catalogue edition your classification was made under. Ask which edition the declaration was prepared against, and diarise the turnover rather than the licence date. This is the one item on the list that genuinely does move on December 31.
Write the answers into the contract rather than collecting them by email. Name the licence type and its expiry, require notice before a licence lapses or an application is refused, and state who bears the delay when a classification changes at a catalogue turnover. The wider licensing playbook — end-use documentation, dual sourcing, Incoterms — is in our procurement strategy under export controls, and the full chronology of what was controlled when is in the China export controls timeline.
Frequently Asked Questions
So is there any December 31, 2026 deadline for dysprosium at all?
Not for the licence. The date is real in Chinese export administration — ordinary export licences may not expire later than December 31 of their year — but dysprosium does not ship on an ordinary export licence. What does fall at year end for dual-use goods is the replacement of the annual licensing catalogue, which can change how your item is classified and declared without touching the validity of your licence.
My freight forwarder told me the licence expires at year end. Are they wrong?
They may be describing the ordinary export licence regime, where that is correct, and applying it to a dual-use item where it is not. Ask which licence type the shipment moves on. If the answer is a dual-use single or general licence, Order No. 792 Article 15 governs and the clock runs from issue, not from January 1.
What changes on November 10, 2026?
The one-year suspension of the October 9, 2025 measures — the extraterritorial and technology controls in Announcements No. 61 and No. 62 — reaches its end date. The April 2025 licensing of the seven medium and heavy rare earths is unaffected because it was never suspended. Whether the suspension is extended, allowed to lapse, or replaced is a policy decision, and we do not have a basis for forecasting it.
Does a general licence mean my supplier can ship without restriction?
No. A general licence authorises repeat shipments within a stated scope, to stated end users, for a stated period of up to three years. Move outside that scope — a different end user, a different item, a different declared end use — and you are back to a per-shipment application. It shortens lead time; it does not remove the control.
Are scandium and yttrium on the same footing as dysprosium here?
Yes for the mechanics. All seven elements in Announcement No. 18 sit under the dual-use system, so none of them is on a December 31 licence clock. Their commercial situations differ sharply, however — the yttrium and dysprosium flows behaved very differently over the first sixteen months, which we traced in the rare earth controls piece, and scandium's position is set out in the SOFC supply chain analysis.
References (Public Sources)
- Regulations of the People's Republic of China on Export Control of Dual-Use Items (State Council Order No. 792), in force December 1, 2024 — Article 15 on validity of single and general licences.
- Measures for the Administration of General Licences for Export of Dual-Use Items and Technologies — Article 6, general licence validity not exceeding three years.
- MOFCOM and General Administration of Customs Announcement No. 91 of 2025, dated December 31, 2025 — 2026 Catalogue of Dual-Use Items and Technologies Subject to Import and Export Licensing, effective January 1, 2026.
- MOFCOM and General Administration of Customs Announcement No. 18 of 2025, April 4, 2025 — export licensing for samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium and their metal, alloy, target, oxide, compound, mixture and permanent-magnet forms.
- MOFCOM Announcements No. 61 and No. 62 of 2025, October 9, 2025 — controls on rare-earth items produced outside China with Chinese content, and on rare-earth technology.
- Reported suspension of the October 9, 2025 measures to November 10, 2026 following US–China talks, and the matching one-year suspension of the US BIS affiliates rule.
- MOFCOM export licence issuing rules — ordinary export licence validity of at most six months, expiry not later than December 31 of the same year, next-year licences issuable from December 10 with effect from January 1.
Dates and licence mechanics above are as published at the time of writing. Licensing practice can change without a public announcement, and we recommend confirming the current position with counsel before relying on it commercially.
Most of the confusion here is not resolvable from the buyer's side, because the answer sits on a document the buyer never sees. Nami Tech Solutions (NTS) deals with the mills directly and in their own language, so the licence type, its issue date and its validity come back as stated facts on a quotation rather than as a forwarder's summary — and where a supplier holds a general licence, we say so, because it changes your lead time more than anything else on the page.
