China's export controls on gallium and germanium took effect on August 1, 2023. Three years is long enough to score the predictions made at the time, and the scoring produces an uncomfortable result: the most widely repeated verdict on these controls — that markets had largely adjusted and licensing was not an embargo — was published in mid-2024, was defensible on the data available in mid-2024, and has been wrong since. Chinese gallium exports rose in 2024 above their 2023 level; unwrought gallium exports then fell 94% in 2025. Anyone reading a one-year-old assessment of this control today is reading a judgement taken at the wrong moment, and the same trap is waiting for the next announcement. This article scores the three years and extracts the one test that turned out to predict which items came back. The sequence of announcements itself is in our export-controls timeline; the general playbook for buying under a licensing regime is in procurement strategy under export controls; the parallel rare-earth episode is in our yttrium analysis.
The Scorecard
Six propositions circulated widely in the first two years. Scored against three years of data:
Two of six are "we could not confirm this." We are not going to fill those in with plausible numbers; the absence is itself the finding, and it disqualifies a great deal of what is asserted confidently about this control.
Why the Verdict Flipped: the Numbers Kept Moving
Germanium is the cleanest series, because a single source reports the same January-to-September window three years running. Chinese germanium metal exports were 36,656 kg in 2023, 18,787 kg in 2024, and 7,520 kg in 2025. There is no recovery anywhere in that line. In 2025, destinations were Russia 28%, Belgium 26%, Germany 26% and Japan 18%.
Gallium did the opposite before it did the same thing. Chinese gallium exports were around 45 t in 2023 and around 54 t in the first eleven months of 2024 alone — we could not confirm a 2024 full-year figure, but eleven months already exceeded the prior full year. Then unwrought gallium exports fell 94% in 2025. That is the shape the 2024 assessments could not see, and it is why a mid-2024 verdict on a control announced in mid-2023 was a verdict taken one data point too early.
The 2026 monthly figures show why any single-month read is also unsafe. Chinese gallium exports ran 6,000 kg in January, 5,000 kg in February and 5,350 kg in March; in April they were 3 kg; in May they were 6,200 kg, of which 6,000 kg went to Japan. Germanium over the same months ran 93, 736, 998, about 2, and 1,134 kg. Three orders of magnitude, month to month, with no new gallium- or germanium-specific control published in between. In March 2026 trade reporting described Japan as effectively cut off from both metals; by May Japan was taking almost all of the month's gallium. Both statements were accurate when written. Read against the monthly figures rather than summed, the 2026 months, April aside, do not look like a continuing collapse — that word describes what happened to unwrought gallium in 2025, not the pace so far this year.
That is what "licensing, not embargo" actually means in practice. It is not a binary. It is a dial that can be turned to near zero by destination, without a new control being published, and it was turned. Enforcement moved the same way: a special campaign against smuggling and transshipment of strategic minerals began in May 2025, and Announcement No. 26 of 2026 established a reporting mechanism for export-control violations effective July 1, 2026.
The Control Group: Why Graphite Came Back and Gallium Did Not
This is the part that transfers to the next announcement. On the same methodology and the same source, with windows anchored to each item's own control date (for gallium and germanium, January 2022–June 2023 against January 2024–October 2025):
The European figures are peak increases within the window, not averages.
Every item in that table sits under the same basic instrument — a licence requirement. The gallium-germanium-antimony group additionally carried the December 2024 US prohibition, but their exports to the US and the Netherlands had already been zero since the day licensing began — the divergence predates the prohibition. The outcomes are not remotely the same either way. Graphite volumes were flat to slightly up and rare earth magnet volumes rose 25%, while unwrought gallium fell 66% and wrought germanium fell 60%. The legal form of the regime did not decide the outcome. What separated the two groups, on the source's own account, was that gallium, germanium and antimony trade in relatively limited markets where China is dominant, while the natural graphite market is larger and has some additional suppliers — and graphite's recovery also coincided with reduced demand growth in the EV sector. Antimony travelled in the same December 2024 package as gallium and germanium and shows the same signature in the table; licence status by compound is set out on the antimony compounds page.
One caution on reading that table alongside our own rare-earth work: the magnet line is finished magnets, not separated oxides. Within the rare earth group the outcome split by item too, and yttrium in particular did not recover — that is the subject of the yttrium analysis, and the two findings do not conflict.
Three mechanisms explain the split, and all three are checkable for your own item.
Inventory buffer. USGS modelling found that up to 58% of Chinese germanium net exports could be absorbed by existing stocks without shifting the supply curve at all. Gallium had no comparable cushion.
Secondary supply. Germanium recycling is a real supply channel: Umicore states that more than half of its germanium feed is its own recycled material, and a Payne Institute review of the North American germanium supply chain reports that the US Defense Logistics Agency recovered 3,000 kg of 99.999% germanium ingot from retired night-vision optics in FY2022. Gallium is the opposite case. USGS reports no old-scrap gallium recycling in the United States. Secondary high-purity gallium capacity is substantial — roughly 280,000 kg/yr against about 340,000 kg/yr of total high-purity capacity — but that stream is manufacturing scrap from device fabrication, not end-of-life material, so it scales with production rather than replacing lost feed.
Concentration at the primary tier. On a primary, low-purity basis China accounts for 98–99% of world gallium output; on refined, high-purity gallium its share is about 50%. Those are different products with different bottlenecks, and quoting one number without saying which tier it refers to is the most common error in coverage of this material. For germanium we do not give a share figure at all: USGS states plainly that world germanium production data are limited and difficult to verify, so the honest statement is that China is the largest producer and exporter.
The asymmetry also shows up in the only quantified economic estimate we could verify. USGS modelled a complete restriction of Chinese net exports at US$3.1 billion of US GDP for gallium alone (range $1.7–8.2bn) and US$0.4 billion for germanium alone (range $0.01–1.1bn), with both together at $3.4 billion. That $3.1bn figure is frequently quoted as the combined gallium-and-germanium impact. It is not; it is gallium by itself, and 46.5% of it falls in semiconductor and related device manufacturing.
Announcements and Funding Are Not Tonnes
Three years of controls produced a great deal of capital commitment. Public money has gone into gallium and germanium recovery in the United States, Canada, Australia and the European Union across 2024 to 2026, and several named projects are underway. What has not yet appeared is production.
In the 2026 USGS edition, primary low-purity gallium production outside China consists of Japan at 3,000 kg and Russia at 6,000 kg, against China at 900,000 kg (estimated for 2025). Korea appeared as a 3,000 kg producer in the 2025 edition and appears in the 2026 edition only as capacity, not production. On USGS's own figures, Korean primary gallium production went from 3,000 kg to nil over the control period.
The named projects, as stated by the companies and in press reporting:
Not one of those lines adds a tonne available to buy in 2026. A May 2026 assessment concluded that the gallium projects it surveyed will not reach full operation before mid-2027 at the earliest. If you are writing a 2027 supply plan against announced capacity, the entries above are the reason to ask the supplier a blunter question: is the material being produced now, and can you ship it this quarter?
A related data-quality note worth carrying: USGS revised China's 2024 primary gallium production from 750,000 kg in its 2025 edition to 839,000 kg in its 2026 edition. Even the reference series moves by more than the entire non-Chinese production base.
Two November Deadlines
Two suspension expiries fall this November and they are not the same instrument. November 27, 2026 is when the suspension of Article 2 of Announcement No. 46 of 2024 — the outright prohibition on gallium, germanium, antimony and superhard materials to the United States — runs out. November 10, 2026 is when the suspension of the October 2025 announcements (rare earths, superhard materials, graphite and lithium battery items) runs out. As of today the November 27 date is roughly three months away. We have not found any public statement on whether either will be extended, and we do not have a basis to predict it in either direction. Which of China's licence clocks actually governs a given shipment is treated in detail in which export licence deadline governs your shipment.
Note also what was never suspended. Article 1 of Announcement No. 46 — the prohibition on exports to US military end users and for military end use — remains in force. And Announcement No. 23 of 2023, the licensing requirement itself, has never been lifted at any point. The November 2025 measure returned gallium and germanium from prohibition to licensing; it did not remove the control — and whether the suspension itself holds through November 27 is addressed below.
Five Things to Follow Before They Pass
Five things follow for a buyer.
Score your own item, not the regime. Ask the control-group questions: does non-Chinese primary supply exist today at your volume, is there a secondary or inventory buffer, and is your market large and diversified enough to support alternative suppliers? Gallium answered no three times. Graphite did not.
Get the classification right on both sides. Gallium and germanium share HS 8112.92 at six digits, and below that the two administrations diverge in the worst possible way: China assigns .10 to germanium, the United States assigns .10 to gallium. Harmonise at six digits and copy the counterparty's subheading and you have swapped the commodity. Related codes worth fixing in the specification are 8112.99 for wrought forms, 2825.60 for germanium oxides and 2827.39 for germanium tetrachloride. We were not able to confirm the Korean HSK ten-digit lines from customs sources and therefore do not state them here.
State the form, not just the element. Unwrought gallium fell 66% while wrought gallium fell 4% under the identical announcement. Make wrought/unwrought status a mandatory field in the RFQ and the PO, not just the HS code — the HS six-digit level does not distinguish them, and the difference is most of your exposure.
Plan diversification in years. Korea's own import mix is the clearest available evidence of how long this takes. Gallium imports were 73.6% Chinese in 2024 and 26.0% in 2025, with Germany at 25.9%, the United States at 24.3% and Japan at 18.2%. Germanium went from 59.3% Chinese in 2023 to 14.8% in 2025, with Canada at 70.7%. That is roughly a two-year movement — and the 2024 number is a warning in itself, because the Chinese share went up that year on front-loaded buying rather than down. Meanwhile indium remained 94.2% Chinese in 2025, graphite 71.0% and tungsten 69.8%. Diversification is item-specific, exactly as the control-group table predicts.
Do not price off a one-year-old assessment. That is the whole lesson of the three years. Outside China, gallium moved from $250–265/kg in June 2023 to a peak of $550–600/kg in spring 2024, $687/kg in May 2025 and a record $1,850/kg in April 2026 — which a May 2026 assessment put at more than 200% above early-2025 levels. Germanium metal in Europe averaged $1,392/kg in 2023, $1,991/kg in 2024 and an estimated $4,100/kg in 2025. Inside China, prices softened in the later part of the period. We do not have a defensible forecast for where either goes next, and we do not offer one. Taken over the period as a whole, the spread between the price inside China and the price outside it has only widened; the source report reads that pattern as a competitive advantage to China-based users, though it also calls the divergence "not straightforward to explain" and points to several contributing factors — trader inventories, a preference for non-Chinese-origin material, and transport costs — and notes that for germanium, much of the European price rise ran in parallel with rising prices inside China as well.
Frequently Asked Questions
Are China's gallium and germanium export controls still in force in August 2026?
Yes. Announcement No. 23 of 2023, which introduced the licensing requirement effective August 1, 2023, has never been lifted. What was suspended in November 2025 was Article 2 of Announcement No. 46 of 2024, the outright prohibition on exports to the United States, and that suspension runs to November 27, 2026. Article 1 of the same announcement, covering US military end users and military end use, was not suspended.
Did the November 2025 suspension bring US-bound gallium and germanium back?
Not on the evidence available. A May 2026 assessment found no sign of a meaningful resumption of US-bound gallium after the Busan meeting, and US germanium metal imports fell 67% in 2025 against 2024. A separate point is often missed: total US gallium metal imports more than doubled in 2025, to an estimated 25,000 kg, at an average unit value up roughly 30% to an estimated $580/kg. The United States bought more gallium, from elsewhere, at a higher price — the Chinese share of US gallium imports fell below 5%, from around 38% in 2022.
What is the difference between November 10 and November 27, 2026?
They are suspensions of different measures. November 10 ends the suspension of the October 2025 announcements covering rare earths, superhard materials and graphite and lithium battery items. November 27 ends the suspension of the US prohibition on gallium, germanium, antimony and superhard materials. If you buy gallium or germanium, November 27 is your date.
How much of the world's gallium does China actually control?
It depends which tier. On primary, low-purity gallium the figure is 98–99% — 99% in the 2026 USGS edition, where the only other primary producers listed are Japan and Russia. On refined, high-purity gallium China's share is about 50%. Shares between 94% and 99% appear in circulation because sources define the production base differently. For germanium we do not quote a share: USGS states that world germanium production data are limited and difficult to verify.
Did China cut Japan off from gallium and germanium?
Reporting in March 2026 described Japan as effectively cut off from both metals, and Japan then received 6,000 kg of gallium in May 2026. Both are correct for their month. A separate measure of January 6, 2026 tightened dual-use controls on exports to Japan, but on an end-use and end-user basis rather than by naming items; the example items reported were tungsten, molybdenum and rare earth magnets, and we have not been able to confirm whether gallium or germanium fall within it.
Has any new non-Chinese gallium plant started commercial production?
Not as of August 2026. Pilot quantities have been produced in Greece and first gallium was extracted in Quebec in May 2025, but the plants concerned are described by their operators as under construction, and a May 2026 assessment placed full operation no earlier than mid-2027.
References (Public Sources)
- USGS Mineral Commodity Summaries, 2024, 2025 and 2026 editions — gallium and germanium chapters, for production, capacity, trade, import sources and price series
- USGS Open-File Report 2024-1057 (Nassar and others, November 2024) — quantified estimates of the effect of Chinese gallium and germanium export restrictions on US GDP
- Swedish Institute of International Affairs and the Swedish National China Centre — report on China's mineral export restrictions, using Chinese customs data with Argus and Fastmarkets price series, for the pre- and post-control volume and price comparison
- Center for Strategic and International Studies — gallium supply chain assessments of July 2025 and May 2026
- Fastmarkets, July 2024 — the one-year assessment that markets had largely adjusted, and the Rotterdam gallium and germanium price points quoted publicly at that date
- Peterson Institute for International Economics, October 2024 — assessment that the controls were a jab rather than a haymaker
- Pillsbury Winthrop; CIRS Group; Center for Security and Emerging Technology, Georgetown — texts, translations and analyses of the 2023, 2024 and 2025 announcements and the November 2025 suspension
- Morgan Lewis, 2026 — Chinese export-control enforcement actions and the 2026 violation-reporting mechanism
- Greenberg Traurig, 2026 — the January 2026 dual-use measure on exports to Japan
- People's Daily Online, July 2025 — MOFCOM statements on transshipment and smuggling enforcement
- TRADIUM and RAWMATERIALS.net — monthly tallies of Chinese customs gallium and germanium export data through 2026
- SMM/metal.com — 2024 gallium market review
- Korea Economic Institute of America and The Diplomat — analyses of Korean critical mineral import diversification based on KOMIS statistics
- METLEN, Rio Tinto, Teck, Nyrstar and Korea Zinc — company statements on gallium and germanium projects, and Korean press reporting on the Onsan smelter figures; Korea Zinc and Lockheed Martin on their germanium supply MOU
- Umicore — germanium sourcing and recycling statements
- Payne Institute for Public Policy — review of the North American germanium supply chain, military applications and civilian competition
Two limits on the above. We cite Chinese announcement numbers as they are reported by law firms and policy databases; we did not obtain and compare the Chinese originals, and we flag that rather than imply a level of verification we did not perform. And the gallium and germanium price series are commercial subscription products — we quote only the individual points that third parties have published, which is why the price figures here are dated points rather than a continuous series.
Nami Tech Solutions (NTS) does not hold gallium or germanium as standing inventory, and nothing above should be read as an offer of tonnage that is not being produced. What we do is project work: fixing the element, the form and the customs classification in one specification document before quotations are compared, putting the licence question to the manufacturer directly in its own language, and writing the licence contingency and the origin documentation into the contract as ordinary terms.
