If you buy ammonium paratungstate (APT), tungsten carbide powder or ready-to-press WC-Co grade powder out of China, the last eighteen months have looked like a wall. Chinese APT exports were 782 t in 2024 and 22.8 t across the first seven months of 2026, with January, February and July at zero. One agency's Rotterdam APT assessment stood at $335–345 per metric tonne unit of WO₃ on January 8, 2025; another's averaged $3,185 on April 9, 2026. If you diarised November 10 and November 27, 2026, you prepared against a clock that does not govern tungsten. The sequence of Chinese announcements is in our export-controls timeline, and which licence clock governs a shipment in the dysprosium deadline piece. This article is about what neither can show: February 2025 was the second control layer laid on tungsten, not the first, and it bites at the level of the customs item code rather than the metal.
Three Layers, and Only the Second One Is New
Layer one: the ordinary export licence. Tungsten sits at entry 24 of China's annual Catalogue of Goods Subject to Export Licence Administration, 「钨及钨制品」, covering concentrates, APT, tungsten oxides, tungstates, tungsten carbide, tungsten powders, unwrought tungsten and scrap. We compared the 2022 and 2026 editions: substantially identical, the only change being that the 2022 entry 8101940000 split into 8101940001 (dual-use-controlled tungsten) and 8101940090 (the rest). Per China's WTO notification, licensing plus state trading has been in force since January 1, 2020, with an earlier form from October 2018. Tungsten has needed an export licence for years, and that has nothing to do with February 2025.
Layer two: the dual-use licence. Announcement No. 10 of 2025 — MOFCOM and the General Administration of Customs, effective immediately on February 4, 2025, no grace period — added this layer, covering tungsten, tellurium, bismuth, molybdenum and indium. It is case-by-case licensing — the text says exporters shall apply for a licence. Its basis is the Regulations on Export Control of Dual-Use Items (State Council Order No. 792, in force December 1, 2024): a different statute, licence and clock from Layer one. The ordinary licence cannot expire later than December 31 of its year; a dual-use single licence runs up to one year from issue and lapses when the export completes. Tungsten is a rare case where a buyer meets both walls.
Layer three: state trading. Only designated enterprises may export tungsten at all. MOFCOM Announcement No. 68 of October 26, 2025 set the qualifying conditions for the 2026–2027 term, and the resulting list, in a notice dated December 26, 2025, followed at the end of that month: fifteen tungsten companies. Note what this is not — the word 配额, quota, does not occur in either 2026 catalogue, and No. 68 sets entry conditions, not tonnages. It is an enterprise designation regime: your export leg must be one of the fifteen or run through one, changing price, title transfer and lead time — a question for supplier qualification, alongside our supplier audit checklist.
And the November dates are not tungsten's dates. Announcement No. 70 of November 7, 2025 suspended the October 9, 2025 measures to November 10, 2026, and Article 2 of Announcement No. 46 of 2024 — the US prohibition on gallium, germanium, antimony and superhard materials — was suspended to November 27, 2026. Announcement No. 10 of 2025 is not among the measures that Announcement No. 70 lists as suspended, and nothing since has suspended it. We read the suspension through law-firm summaries rather than the original text; what we did read in full is the 2026 dual-use catalogue, which carries the tungsten entries in force from January 1, 2026, and the January 6, 2026 measure on Japan, which names tungsten items — neither is the act of a control on pause. (The 0.1% extraterritorial de minimis rule doesn't reach tungsten either; see below.)
The Control Climbs to Grade Powder and Stops at Sintering
The dual-use layer is written as control numbers with customs item-code references, and the boundary it draws is not "raw material versus finished goods."
The tungsten entries created by Announcement No. 10 did not reach the annual catalogue until January 1, 2026. Control numbers 1C004, 1C117 and 1E004 appear nowhere in the 2025 edition and appear in the 2026 edition (Announcement No. 91 of 2025). Through 2025 the control ran on the announcement itself; the 2025 catalogue had simply not caught up yet.
Tungsten metal powder was already controlled before February 2025. Entry 1C111.b.1.f — particles under 500 µm of the relevant metal or alloy at 97 wt% or above, referenced to 8101100010 — is in the 2025 edition with identical wording, and commercial tungsten metal powder generally satisfies both conditions. One limit: 1C111 sits under a solid-propellants heading, and we could not determine whether that heading imposes an operative end-use requirement.
Ready-to-press WC-Co powder was added to the reference codes in the 2026 edition. Announcement No. 10's original text put only 2849902000 under 1C117.d.3; the 2026 catalogue lists 2849902000, 3824300010 and 3824999923 there. Code 3824300010 is 「混合的未烧结金属碳化钨（包括自身混合或与金属粘合剂混合的）」 — unsintered mixed metal tungsten carbide (non-agglomerated in HS terms), including material mixed with a metallic binder — grade powder with cobalt in it. Reference codes are references; the item description governs. But "ours is a Co-bearing blend, not pure WC, so it's outside the control" now argues against a documented basis for customs to ask for a licence. We could not confirm whether licences are being demanded on that code, or from what cobalt content.
What is not on either list, verified by full-text search of the 168-page dual-use catalogue and the 59-page ordinary licensing catalogue: HS 8209 (sintered inserts and tips), HS 8101.96 (tungsten wire), ferro-tungsten (long on the ordinary licensing list, never the dual-use one), and the term 硬质合金 itself. That absence is verified; that finished inserts export freely is only an inference from it, not a positive statement in Chinese law — confirm with a customs broker first. Target classification is treated separately in the sputtering target import guide.
So the line on the bill of materials is not "raw material versus finished part." It is compaction and sintering. The control climbs as far as press-ready grade powder and stops there.
Item Codes, Not Metals: What the Trade Data Show
Chinese tungsten product exports were 15,514.7 t in 2025 on a physical-weight basis, down 19.7%, or 13,095.7 t on a contained-metal basis, down 20.0%. A Chinese tungsten industry association put the same year at 15,300 t, down 20.71%, on a narrower scope. The two do not reconcile because they measure different baskets, and neither is "the" figure.
Inside that aggregate the controlled subset — APT plus tungsten powder plus tungsten carbide powder — fell 41.7%, to about 3,877 t. This is where the widely repeated claim that China cut tungsten exports by 40% comes from: it is a controlled subset presented as the whole. The whole fell about 20% in 2025 and 13% (smelted products and materials) in January–July 2026.
APT is the clearest line: 782 t in 2024, 243 t in the first eleven months of 2025, zero in January and February 2026, zero again in July, and 22.8 t across January–July 2026, down 88.8% year on year. January–February's zero was partly the Lunar New Year lull; July had no seasonal cause. The measure is not a ban — the announcement text, Korea's ministry and Masan High-Tech Materials all say so, the company's own words: "It is not a ban, but these measures inevitably create different pricing dynamics." For APT specifically the outcome is nonetheless hard to distinguish from one.
The forms outside the dual-use list went the other way. Across January–July 2026: tungsten bars, rods and profiles 354.3 t, up 53.3%; tungsten hexafluoride 335.6 t, up 39.1%. One controlled line moved the same way — tungsten carbide, 1,209.7 t, up 26.6% against a 2025 base that had fallen with the rest of the controlled subset — which is the reminder that licensing is not the same thing as stopping; it is APT specifically where the outcome resembles a halt. Cemented-carbide items, on neither list, were flat to down — cutting tools fell 1.5% in 2025, inserts 15% in January–July 2026. Smelted products and materials over January–July 2026 totalled 7,781 t, down 13%. One caution: the source's monthly and cumulative tungsten carbide figures don't reconcile, so we quote cumulative totals only.
Prices: Get the Unit and the Series Right
The unit is US dollars per metric tonne unit of contained WO₃. One mtu is 10 kg of WO₃, containing 7.93 kg of tungsten on the USGS figure. Trade press and at least one earnings-call transcript have printed APT at "$3,150 per metric ton," which is wrong by a factor of a hundred.
The series are not interchangeable. For 2025 the Argus series reported via USGS shows Rotterdam APT rising from $331 to $675/mtu across the year, while one agency assessed $830–870/mtu CIF Rotterdam on December 12, 2025, and another printed $1,050–1,115/mtu for December 31 in a report on Chinese prices whose Incoterm we could not pin down — that agency's own CIF Rotterdam figure for January 2026 was $900–940/mtu, so the higher number is more likely FOB China. Different assessments, and probably different Incoterms, not competing opinions about one price. On September 3, 2026, APT CIF Rotterdam was assessed at $3,000/mtu and ferro-tungsten at $210/kg W CIF Rotterdam against $180/kg W FOB China.
And the inside/outside split reached the gallium outcome by a different road. In the gallium scorecard what widened the spread was that the price inside China retraced while the price outside did not. Tungsten ends in the same place, but got there differently: through 2025 the two rose together, and on December 12, 2025 one publisher assessed European APT at $830–870/mtu CIF Rotterdam against Chinese domestic APT at 555,000 CNY/t, self-converted to about $887/mtu — roughly 4% dearer inside China, on our arithmetic. The split opened in 2026 because the domestic price fell: on the same 88.5 divisor — one tonne of 88.5%-WO₃ APT is 88.5 mtu — and this arithmetic is ours since no third party publishes a spread, Rotterdam ran about 2.06× the Chinese domestic price on May 8, 2026 and 3.40× on September 3–4. Chinese concentrate fell by more than half from a March 2026 peak, largely on weak domestic demand. Attributing the whole spread to export controls would be an overstatement. What licensing does explain is why the two no longer arbitrage — "the correlation between China and non-China prices has broken down materially," as one Masan executive put it.
Which Tier Are You Quoting?
"China controls 80% of tungsten" is true only of the least important tier, so the sentence has to carry a tier every time.
Mine production: China produced 66,000 t of contained tungsten in 2023 and 67,000 t in each of 2024 and 2025, against a world total that rose from 79,500 t to 85,000 t. China's share fell from 83.0% in 2023 to 78.8% in 2025 — not because China produced less but because the world produced more, the largest single contributor being a Kazakh deposit that went from nothing in 2024 to 2,400 t in 2025 and whose operator is a Hong Kong-listed Chinese-owned company. Non-Chinese mine supply in 2025 was 18,000 t.
Reserves: China holds 2,500,000 t of a world total above 4,700,000 t, at most 53.2%.
Conversion to APT and carbide — the tier that actually binds — has no official figure at all, and that absence is documented. The European Commission's critical-raw-materials factsheet states that at the processing stage "there is no official public source of information on the global production of processed tungsten," and could not compute a supply-risk value for it. USGS publishes only a count of seven US converters, with no tonnage. We do not give a conversion percentage.
National dependence figures carry the same problem in another form, and Korea's are the clearest illustration. Korea's dependence on Chinese tungsten is widely quoted at 69.8% for 2025 against 85% for 2024, read as diversification. On a wide basket including concentrate, ferro-tungsten, metal products and scrap — reproduced from Korea Customs Service raw statistics — 2025 comes out at 69.2% by value and 69.9% by weight, confirming the 69.8%. But the 85% used a narrower basket of tungsten oxide, tungstates and tungsten carbide only, reproducing exactly at 85.1% for 2024. Run 2025 on that same narrow basket and it is 89.3%. Measured like for like, dependence went up. The two figures differ by basket, not by year, which is why a dependence percentage without its basket is worthless.
One tier we leave open is secondary supply. The recycling figures in circulation — a 35% recycling input rate, for instance — measure scrap against intermediate input, not demand, and date from 2016; on an end-of-life basis the industry figure is closer to 30%, and production scrap and spent inserts are already recovered near 100% and above 95% respectively — the easy part is done. In Q1 2026 US tungsten scrap exports ran about three times the year-earlier level, Chinese buyers were reported bidding up to five times the going rate, and a US industry coalition asked for scrap export licensing in response: the buffer exists, and it is being bid away by the country that imposed the control.
What to Put in the RFQ, the PO and the Contract
The general playbook for buying under a licensing regime is in our procurement strategy guide; what follows is specific to tungsten.
Make form and agglomeration state mandatory fields. They decide control status and customs classification together: unmixed WC powder is heading 2849.90; WC mixed with a metallic binder but non-agglomerated is 3824.30; agglomerated or sintered material is 8113.00; sintered tool tips are 8209.00.
Write down the numbers that decide the control determination: tungsten content in wt% (97% in 1C117, 80% for W-Cu and W-Ag), particle size (50 µm in 1C117.a on Korea's list, 500 µm in 1C111.b.1), the dimensional thresholds in 1C117.c, and for heavy alloy the density, elastic limit, tensile strength and elongation of 1C004. One warning there: the Chinese 2026 catalogue prints the 1C004 elastic limit as over 800 MPa while Korea's Public Notice on Trade in Strategic Items (전략물자수출입고시, Notice No. 2026-101) prints 880 MPa. We could not determine which is right, so an order between the two figures should be treated as controlled.
Ask three questions of the exporter before price. Is the exporting entity one of the fifteen designated state-trading enterprises? Which licence is this shipment moving on, and has a general licence ever been issued for it — we found no confirmed instance for tungsten. And has the application been accepted (受理), not merely submitted? The statutory 45-working-day review runs from acceptance, excluding time spent on identification, expert consultation and site inspection — a milestone tied to the application date measures nothing. Lead times run longer: trade press quotes licences taking months. Any change of item, destination, end user or end use requires a fresh licence.
Settle end-user documentation before it is urgent. A company-issued end-user certificate is the baseline; a government-issued or authenticated one is discretionary — the regulation says MOFCOM may require it. On the Korean side there is no import licence for new tungsten material — the Public Notice on Trade in Strategic Items (Notice No. 2026-101, effective September 1, 2026) creates only a discretionary Import Purpose Certificate.
Name the price assessment properly. "The European APT price" is not a contract term — one agency's Rotterdam assessment is CIF duty-free, another's duty-unpaid in-warehouse. Write the institution, assessment name, code, unit, publication day and a fallback if publication ceases, with the unit as US$/mtu of contained WO₃, never "per mtu of APT." Ask for a cap or collar: the largest Western tungsten offtake on record is mtu-denominated and index-linked, while a smaller defence-linked offtake by the same miner carries a floor price with no cap — a structure that favours the seller.
Finally, form moves the downstream burden too. In Korea, cobalt metal with tungsten carbide is item 250 on the list of substances subject to intensive management, and the K-REACH grace period for CMR-designated substances at one tonne a year ended December 31, 2021. A sintered insert has a credible exemption argument as an article; a powder does not. On the certificate of analysis, ask for total carbon and free carbon on carbide powder, because the two errors cancel in the total. Which fields a COA must carry, and how, is worked through in our sample evaluation protocol. Where the item is a tungsten salt, the control determination has to come before the quotation, as the specialty metal compounds page already does.
Frequently Asked Questions
Does the November 2026 deadline apply to tungsten?
No. November 10 and November 27, 2026 are suspension expiries for the October 2025 announcements and for the US prohibition in Article 2 of Announcement No. 46 of 2024. Tungsten entered control through Announcement No. 10 of February 4, 2025, which is not among the measures listed as suspended and, on every source we could read, remains in force; the 2026 dual-use catalogue carries its entries. The 0.1% extraterritorial rule does not reach tungsten either — it targets foreign-made rare-earth permanent magnets and sputtering targets containing certain dual-use rare-earth metals or alloys, a different item class from tungsten entirely.
Are cemented-carbide inserts controlled?
Not on either Chinese list: we searched both 2026 catalogues in full and found no HS 8209 entry and no occurrence of 硬质合金 — a verified absence, not an affirmative exclusion in Chinese law, so confirm with a customs broker first. Ready-to-press WC-Co grade powder is different — the 2026 catalogue lists 3824300010 under 1C117.d.3.
Did China cut tungsten exports by 40%?
No. Total tungsten product exports fell 19.7% in 2025, and smelted products and materials 13% in January–July 2026. The 41.7% figure applies to the controlled subset alone — APT plus tungsten powder plus tungsten carbide powder — reported as the total, the most frequently repeated error about this control.
Will controls ease, and where do prices go from here?
We do not know and have no basis for saying. Since February 2025 the direction has run one way: tungsten was excluded from the November 2025 suspensions, a January 6, 2026 measure prohibited, rather than merely licensed, certain dual-use exports to Japan on an end-use basis naming tungsten, and a violation-reporting mechanism took effect July 1, 2026. We found no instance of easing on tungsten, and we do not forecast prices.
Does the Sangdong mine make Korea self-sufficient in tungsten?
No. Phase 1 average annual production is given as 231,200 MTU of WO₃ in the technical report, converting to roughly 1,833 t of contained tungsten a year — about 2.2% of world mine production and 10.2% of non-Chinese supply. Saleable concentrate began in mid-2026, eighteen to twenty months late, and about 90% of Phase 1 is committed to a Plansee-group converter. Korea has no confirmed concentrate-to-APT plant: it mines tungsten and buys the powder back.
References (Public Sources)
- MOFCOM and General Administration of Customs Announcement No. 10 of 2025, February 4, 2025, on tungsten, tellurium, bismuth, molybdenum and indium; text cross-checked against two republications.
- The dual-use licensing catalogue, 2026 and 2025 editions (Announcements No. 91 of 2025 and No. 67 of 2024), and the export licence administration catalogue, 2026 and 2022 editions — all four obtained in full and compared entry by entry.
- Regulations on Export Control of Dual-Use Items (State Council Order No. 792); MOFCOM Announcement No. 68 of 2025 and the December 2025 state-trading designation notice; Announcements No. 70 of 2025, No. 1 of 2026 and No. 26 of 2026, read through law-firm analyses rather than the originals; the World Trade Organization Quantitative Restrictions database.
- USGS Mineral Commodity Summaries 2025 and 2026, tungsten chapter, for production, reserves, the mtu conversion factor, US converter counts and the Argus-sourced Rotterdam series; the European Commission Joint Research Centre critical raw materials factsheet on tungsten.
- Fastmarkets, SMM and a Chinese tungsten industry association for dated APT, concentrate and ferro-tungsten assessments and Chinese customs tallies through August 2026. These are subscription products; we quote only individual points as published, naming the series since the assessments are not interchangeable.
- Almonty Industries filings with the US Securities and Exchange Commission; Korea Customs Service trade statistics via its open API, queried September 2026; Korea's Ministry of Trade, Industry and Energy release of February 6, 2025; the Public Notice on Trade in Strategic Items, Notice No. 2026-101.
Where we could not confirm something — whether customs is demanding dual-use licences on ready-to-press powder, whether the solid-propellant heading imposes an end-use condition on tungsten metal powder, whether any general licence has been issued for tungsten — we have said so rather than filling the gap with a plausible sentence.
Nami Tech Solutions works project by project on ceramic and specialty-metal materials rather than from standing inventory, and does not supply cemented carbide. On tungsten our work sits above the quotation: pinning down the form, the agglomeration state and the thresholds that decide whether an item is controlled at all, and putting the licence and state-trading questions to the Chinese side in its own language.
