If you buy spherical graphite, coated spherical graphite or anode material out of China, or buy anode from a Korean maker that does, you have probably been told that China "controls graphite" and that November 10, 2026 is the date to watch. Both are incomplete. The control is not a wall around a material but a line drawn at a specific place in two production chains. On the natural side it already runs through coated spherical graphite — the anode feedstock itself — and has since December 2023. On the synthetic side it does not reach anode material at all today, because the layer that would have reached it was suspended the day before it was due to take effect. The sequence of announcements is in our export-controls timeline; this article is about where the line falls, what the trade data show on each side of it, and what a buyer should write down as a result, as of late September 2026.
The December 2023 Layer: All Natural Flake, Only Some Synthetic
The control in force is Announcement No. 39 of 2023, issued by MOFCOM and the General Administration of Customs on October 20, 2023 and effective December 1, 2023. We read the original. Its Article 1 has two lines, drawn on entirely different principles.
Synthetic graphite is controlled only if it meets three thresholds at once: purity above 99.9%, flexural strength above 30 MPa and density above 1.73 g/cm³. MOFCOM's export-control FAQ on graphite, published March 15, 2024, says the three must be met simultaneously and states the consequence in so many words: synthetic graphite powder has no flexural-strength indicator, cannot meet all three, and "is not within the current scope of dual-use control." Synthetic anode material is a synthetic graphite powder. Petroleum coke and needle coke are not named anywhere.
Natural flake graphite is controlled with no qualifier at all. The second line reads "natural flake graphite and its products (including spheroidized graphite, expanded graphite, etc.)." No purity threshold, no particle size, no grade. The reference codes on that line include 2504109100, spheroidized graphite, and 3801901000, which a Chinese tariff database describes as surface-treated spheroidized graphite — coated spherical graphite, the material a natural-graphite anode is made of. We found no MOFCOM text that says "natural graphite anode" in words; that it is reached is our reading of the item description plus the listed code, not a statement MOFCOM has made. The Swedish Institute's customs tables label the same line ‘spheroidized graphite produced by surface treatment (also known as coated spherical graphite)’, so the description is not ours alone.
The common shorthand gets this backwards. "China controls high-purity graphite" is true of synthetic graphite and wrong of natural graphite, where purity is irrelevant. The shorthand in our own timeline row, "high-purity, spheroidized, etc.," should be read with that in mind.
Nor did graphite control begin in 2023. MOFCOM's spokesman said on the day that three high-sensitivity items, spheroidized graphite among them, were being moved from temporary control onto the dual-use list, and five low-sensitivity items, including furnace carbon electrodes, released. The earlier instrument, Announcement No. 50 of 2006, had imposed temporary controls from September 1, 2006. On MOFCOM's own account, spherical graphite has been under some form of export licensing for twenty years.
The layer now sits in the annual catalogue. The 2026 dual-use licensing catalogue (Announcement No. 91 of 2025) carries the synthetic line as 1C108.b and the natural line as 1C108.c. Two reference codes changed from the 2023 text — 3801100030 became 3801100040, and the expanded-graphite code 3824999940 became 3824999921 — which we established by comparing the documents; neither says why. The catalogue also says a licence is required whether or not an item's code is listed: the codes are references, the description governs. Graphite is not on the 2026 ordinary export licence catalogue; we searched it in full. Which licence clock governs a shipment is set out in which export licence deadline governs your shipment; for graphite it is the dual-use one.
The Anode Layer That Never Took Effect, and Graphite's Two November Dates
Announcement No. 58 of 2025, dated October 9, 2025, was aimed at the anode itself. Its graphite section lists synthetic graphite anode material (3C901.b.1) and anode material blending synthetic and natural graphite, which the official text numbers "3C902.b.2" — the sequence suggests 3C901.b.2 was meant; we quote it as printed. It also lists granulation and coating equipment above stated sizes, four types of graphitization furnace, and three process technologies.
Three things are missing. There is no customs code for either anode item. There is no performance threshold for either — no capacity, density or particle size — so the 330 mAh/g and 80% graphitization figures that get attached to it do not come from here; they are the product definition in the US anti-dumping case. And pure natural-graphite anode is not listed — on the reading above, it was already inside the 2023 layer.
It has never been in force. Its stated effective date was November 8, 2025. Announcement No. 70 of November 7, 2025 suspended Announcements No. 55, 56, 57 and 58 and MOFCOM Announcements No. 61 and 62 "from today until November 10, 2026," with no partial language — a day before the effective date. The 2026 catalogue has no 3C901, 3C902, 3B901 or 3E901 entry. Today a Chinese exporter of pure synthetic anode needs no dual-use licence on any document we found; blends are a separate question, taken up below.
Graphite has a second November date. Article 2 of MOFCOM Announcement No. 46 of December 3, 2024 said licences for gallium, germanium, antimony and superhard materials to the United States would in principle not be granted, and imposed stricter end-user and end-use review on graphite dual-use items to the US. Announcement No. 72 of November 9, 2025 suspended Article 2 until November 27, 2026; Article 1, on US military end users and uses, was not suspended. Our gallium and germanium scorecard describes November 27 as a gallium, germanium, antimony and superhard-materials date. It is a graphite date too, for US-bound shipments.
So November 10 ends the suspension of the anode layer, for all destinations; November 27 ends the suspension of stricter US review of the 2023-layer items. Neither touches the December 2023 layer, which has never been suspended. As of this article's date we found no announcement extending, lifting or modifying either suspension; the dates are 46 and 63 days away. What happens on them is a question we do not take up here.
What the Trade Data Show on Each Side of the Line
Licensing produced a sharp stop, then an uneven recovery. In January 2024 MOFCOM's spokesman said the control "is not a ban on exports" and that compliant applications had been approved; the question put to him cited reported approvals for spherical graphite and anode bound for major Korean battery makers. Fastmarkets reported in April 2024 that approvals typically took more than a month. We found no published approval or denial counts. In January–February 2024 Chinese flake exports fell 77.66% year on year and spherical 64.54%, per Fastmarkets' reading of customs data.
Over a longer window the line shows in the numbers. The Swedish Institute of International Affairs compared average monthly Chinese exports in January 2022–September 2023 with March 2024–October 2025:
The same report finds spherical exports to the United States ceased completely from May 2025, coated spherical exports to the US shrank to near zero from April 2025, and natural graphite exports to India ceased after implementation.
USGS reports the intermediates recovering further in 2025: in the first nine months, natural graphite exports were 115,000 t, up 6%, and spherical purified graphite 37,400 t, up 29%, of which Korea took 40%, Indonesia 33%, Japan 16% and the US 11%. That US share does not sit easily with the Swedish finding, and we could not reconcile the two. USGS attributes Indonesia's rise to new Chinese-owned spherical graphite capacity there. In August 2026, per SMM, Chinese flake exports were 6,360 t, down 2% year on year, and artificial graphite 57,867 t, up 3.1%. We found no 2026 year-to-date totals.
Prices went down, not up. Fastmarkets' flake 94% C, −100 mesh, FOB China was $830/t on January 5, 2023 and $450–470 on October 31, 2024; spherical 99.95% C, 15 µm, FOB China went from $2,500–2,800 to $1,700–2,000 over the same span. European flake spot rose about 15% at its peak after implementation. We could not open any 2026 assessment of spherical or anode prices and quote none.
What this does to "graphite came back." The scorecard's control-group row — natural graphite +2% volume, −30% unit value, +15% European spot — accurately transcribes the flake line in the Swedish report. For flake and artificial graphite volumes, "came back" holds. For the battery intermediates it holds less well, and for the United States as a destination for spherical and coated material it did not hold at all. The scorecard is right about the line it quotes; for an anode buyer it is incomplete. The anode layer offers no evidence either way, having never taken effect.
Korea: The Dependence Sits at the Spherical Stage
POSCO Future M's securities registration statement of June 5, 2025 is the plainest public statement of where the exposure sits. The company describes itself as Korea's only graphite anode maker, makes natural-graphite anode at Sejong, and states that it imports its spherical graphite entirely from China, warning that a supply restriction "can occur at any time." The same filing says more than 99% of spherical graphite is made in China. The company is investing in its own spherical graphite subsidiary — 277.3 billion won of that offering is allocated to it, while KED Global reported 396.1 billion won of board-approved investment; we do not merge the two — and, at POSCO Group level, in Tanzania's Mahenge mine; the company signed for Syrah's Balama graphite in March 2024 (per KED Global). Its synthetic chain runs on needle coke from its own subsidiary, made from steelworks coal-tar by-product rather than Chinese coke.
The national dependence figures disagree because they measure different baskets. The Korea International Trade Association put China's share at 97.7% for natural graphite (HSK 2504.10-9000, on Korea's 10-digit tariff classification) and 94.3% for synthetic (HSK 3801.10-1000), by value, in January–September 2023. The Diplomat gave 71.0% for 2025 from KOMIS statistics, basket unstated — the figure our scorecard used. The Seoul Economic Daily gave 90.34% for January–May 2026, citing the state mineral resources corporation, basket also unstated. The 71.0% is not wrong as quoted, but it is the lowest of these three, and neither it nor the 90.34% comes with an identifiable basket; only KITA's series does. None shows diversification of the kind Korea achieved in gallium.
Graphite is one of ten strategic critical minerals in Korea's February 2023 strategy, which targets dependence on a specific country in the 50% range by 2030. We found no Korean import-side control on graphite.
The US Overlay Is Smaller Than Reported
If your anode or cells go to North America, one frequently cited US measure does not exist. In the anti-dumping and countervailing case on active anode material from China, Commerce's final determinations of February 10, 2026 set 93.50% for separate-rate companies and 102.72% China-wide on dumping, and 66.86% all-others on subsidies. But in March 2026 the US International Trade Commission determined (determination filed March 31, published April 3) that the establishment of a US industry was not materially retarded by those imports, and no orders were issued. We found no appeal to the Court of International Trade, and do not claim there was none.
Section 301 duty on natural graphite (HTSUS 2504.10.10, 2504.10.50, 2504.90.00 in the US Harmonized Tariff Schedule) rose to 25% from January 1, 2026; synthetic graphite is not in that tranche, and we could not confirm what earlier rate, if any, applies to it. The 30D vehicle credit, where graphite had a foreign-entity exemption to 2027, ended for vehicles acquired after September 30, 2025; the live exposure is the 45X credit's foreign-entity cost-ratio test, which we have read only through law-firm and accounting-firm summaries.
What to Put in the RFQ, the PO and the Contract
The general playbook is in our procurement strategy guide; what follows is specific to graphite.
Make chain position a mandatory field. Natural or synthetic; flake, spheroidized or coated; for anode, the natural-to-synthetic ratio. These decide control status today. The blend is the unsettled case: whether an anode containing natural flake-derived graphite is caught by the 2023 layer as a flake "product" is not answered in any document we found. Treat a blend as potentially controlled and ask how previous shipments were declared.
For synthetic material, write down the three numbers — purity, flexural strength where it exists, density — and if the exporter treats the powder as uncontrolled on the strength of the March 2024 FAQ — the best public basis, though the FAQ itself says it is for reference only and the announcement governs — ask it to say so in writing.
Ask which licence the shipment moves on. For natural graphite and its products the answer must be a dual-use licence. A supplier that says spherical or coated spherical graphite needs none is either wrong or declaring the goods as something else, and both are your problem at the border. Whether it has obtained licences for this item before belongs in supplier qualification.
Do not rely on codes alone. The Chinese reference codes changed between 2023 and 2026 and are references in any case. We could not confirm the Korean HSK line for coated spherical graphite or finished anode and do not state one. Put the item description in the specification and let the code follow.
State the destination and the end use before the application, particularly for anything bound for the United States, where stricter review is suspended only to November 27.
Put the licence contingency on a deadline, not on a refusal, for the reasons set out in the procurement guide.
Ask where the spherical stage was done. "Non-Chinese" anode can mean a Korean maker running on Chinese spherical graphite, or Indonesian-origin material from Chinese-owned capacity. For a North American customer's 45X accounting or for your own risk, trace the chain to that stage and put its origin in the documents. We have not assessed non-Chinese anode capacity itself here; verifying a given supplier's actual origin and ownership is diligence the buyer still has to do.
Name the price series — publisher, carbon content, particle size, Incoterm, publication date, fallback. "The spherical graphite price" is not a contract term.
Frequently Asked Questions
Has China banned graphite exports?
No, it licenses them. MOFCOM said in January 2024 that the control "is not a ban on exports," and Chinese flake and artificial graphite volumes were at or above pre-control levels on the Swedish Institute's windows. Two destination outcomes do resemble a stop: spherical graphite to the United States from May 2025, and natural graphite to India.
Is synthetic graphite anode controlled?
Not today. The 2023 layer controls synthetic graphite only where all three thresholds are met, and MOFCOM's FAQ says synthetic powder does not meet them. Synthetic anode is named in Announcement No. 58 of 2025, which was suspended before it took effect and remains suspended to November 10, 2026.
Does November 10, 2026 end the graphite control?
No. It ends the suspension of the October 2025 anode layer. The December 2023 layer, covering all natural flake graphite and its products including coated spherical graphite, has never been suspended. November 27, 2026 separately ends the suspension of stricter review of graphite exports to the United States.
Are US anti-dumping duties in force on Chinese anode material?
No. Commerce made affirmative final determinations in February 2026, but the International Trade Commission's negative determination meant no orders were issued. Section 301 duty of 25% does apply from 2026 to natural graphite under HTSUS 2504.
How dependent is Korea on Chinese graphite?
Heavily on every published basket, though the figures differ: 97.7% natural and 94.3% synthetic in January–September 2023 on defined HSK lines, 71.0% for 2025 and 90.34% for January–May 2026 on unstated baskets. At the spherical stage, POSCO Future M, which describes itself as Korea's only graphite anode maker, states that it imports all of its spherical graphite from China.
References (Public Sources)
- MOFCOM and General Administration of Customs Announcement No. 39 of 2023 (October 20, 2023), original text, and the MOFCOM spokesman's explanation of the same date, read via a China.com.cn reprint.
- MOFCOM export-control information site, FAQ on graphite dual-use items, March 15, 2024; Announcement No. 50 of 2006, whose item table is an image we could not read.
- The 2026 dual-use licensing catalogue (Announcement No. 91 of 2025) and the 2026 export licence administration catalogue (Announcement No. 89 of 2025), both obtained in full and searched.
- MOFCOM and General Administration of Customs Announcements No. 58 of 2025 (October 9, 2025) and No. 70 of 2025 (November 7, 2025); MOFCOM Announcements No. 46 of 2024 (December 3, 2024) and No. 72 of 2025 (November 9, 2025), all read in the original; MOFCOM press conference of January 18, 2024.
- USGS Mineral Commodity Summaries 2025 and 2026, graphite chapter, for Chinese export compilations and recipients.
- Swedish Institute of International Affairs, Report No. 4 2025, on China's mineral export restrictions.
- Fastmarkets export reporting and dated price assessments from 2023 and 2024; SMM monthly Chinese customs tallies for August 2026.
- POSCO Future M securities registration statement of June 5, 2025 (DART); KED Global, April 2025.
- KITA brief No. 18 (ISSN 2765-6004), October 31, 2023; The Diplomat, June 2026; Seoul Economic Daily, June 24, 2026; Ministry of Trade, Industry and Energy critical minerals strategy, February 27, 2023.
- US Federal Register notices on active anode material from China (Commerce final determinations, February 2026; ITC determination, published April 3, 2026); USTR Section 301 modifications notice of September 12, 2024; law-firm and accounting-firm summaries on the 30D termination and 45X foreign-entity rules.
What we could not confirm: whether a synthetic-natural blended anode is caught by the 2023 layer; whether amorphous natural graphite is covered; the Korean HSK line for coated spherical graphite and anode; the baskets behind the 71.0% and 90.34% figures; whether the ITC determination has been appealed; the Section 301 rate on synthetic graphite; and any 2026 spherical or anode price we could open ourselves. We have said so where each arises rather than fill the gap.
Nami Tech Solutions does not make anode material and does not hold graphite as standing inventory. On graphite our work is project by project: fixing the chain position, the grade and the control determination in one specification before quotations are compared, putting the licence question to the Chinese exporter in its own language, and tracing where the spherical stage was done when origin matters to the buyer's customer.
