China
CN · actor dossier
Supply-chain position
The dominant incumbent. China mines roughly 60–70% of the world's rare earths and processes about 90%, and is the leading refiner for 19 of 20 strategic minerals tracked by the IEA. Its principal policy instrument is export licensing and control administered through MOFCOM and customs (GACC), increasingly with extraterritorial reach.
Framing posture
Frames controls as national-security and non-proliferation measures consistent with international practice and dual-use obligations. Official text avoids the language of retaliation even when measures track external trade actions.
Framing anchors (17)
How this actor justifies its policy, in its own words.
为维护国家安全和利益EN to safeguard national security and interests
Justification clause of Announcement No. 61 (2025), verified verbatim against the MOFCOM primary. Re-anchored 2026-08-11: the claim previously cited a third-party bilingual translation and the wording coded at that time (为了维护国家安全和国家利益) does not appear in the announcement, despite a note asserting it was reproduced from the primary. Unlike Announcement No. 46, this text carries no non-proliferation clause, so only national security is coded. This re-anchoring was lost to an accidental working-tree revert on 2026-08-12 and restored the same day by re-fetching the primary and re-reading the clause.
The move was made to safeguard national security and interests and to uphold international commitments including non-proliferation, according to a statement released on MOFCOM's website on Thursday.
Chinese state-media (Global Times English edition) rendering of MOFCOM's rationale. Pairs the national-security justification with a normalization framing — that the controls are consistent with international practice and dual-use obligations.
为维护国家安全和利益EN to safeguard national security and interests
Justification clause of Announcement No. 23 (2023), verified verbatim against the MOFCOM primary. Re-anchored 2026-08-10: the claim previously cited a state-media English report that does not carry the Chinese text, and the wording coded at that time was a near-paraphrase that does not appear in the announcement. The announcement carries no non-proliferation clause, so only national security is coded — a real, narrower framing than the rare-earth and tungsten measures, and identical to the graphite announcement.
为维护国家安全和利益、履行防扩散等国际义务EN to safeguard national security and interests, and to fulfil international obligations including non-proliferation
Justification clause of Announcement No. 46 (2024), verified verbatim against the MOFCOM primary. Re-anchored from CSET's bilingual translation to the primary: the wording coded from CSET (为了维护国家安全和利益,履行防扩散等国际义务) differs from the announcement, which reads 为维护国家安全和利益、履行防扩散等国际义务 — no 了, and an enumeration comma rather than a full comma. The English is the project's own rendering and now carries 等国际义务 ("and other international obligations"), which the previous translation dropped. The category follows the literal text (national security + non-proliferation/compliance); the retaliation reading rests on the one-day-after-BIS timing and is recorded in the event's analytical significance, not the quote. This re-anchoring was lost to an accidental working-tree revert on 2026-08-12 and restored the same day by re-fetching the primary.
为维护国家安全和利益、履行防扩散等国际义务EN to safeguard national security and interests and fulfil international obligations such as non-proliferation
Statutory justification clause of Announcement No. 18 (2025), from the MOFCOM primary. Pairs the national-security justification with the non-proliferation/compliance clause, the same framing as Announcement No. 46.
为维护国家安全和利益EN to safeguard national security and interests
Justification clause of Announcement No. 39 (2023), from the MOFCOM primary. The graphite announcement text does not carry the non-proliferation clause, so only national security is coded — a real, narrower framing than the rare-earth and tungsten measures.
为维护国家安全和利益、履行防扩散等国际义务EN to safeguard national security and interests and fulfil international obligations such as non-proliferation
Justification clause of Announcement No. 10 (2025), from the MOFCOM primary. Same national-security + non-proliferation/compliance clause as Announcement No. 18 and No. 46.
为维护国家安全和利益、履行防扩散等国际义务EN to safeguard national security and interests and fulfil international obligations such as non-proliferation
Justification clause of Announcement No. 33 (2024), from the MOFCOM primary (inspected 2026-07-09). Identical national-security + non-proliferation formula later used in Announcements No. 10 and No. 18 of 2025 — the antimony measure is where this now-standard clause entered the mineral-controls series.
中方将暂停实施10月9日公布的相关出口管制等措施一年EN China will suspend implementation of the relevant export-control and other measures announced on 9 October for one year
From the MOFCOM spokesperson Q&A on the Kuala Lumpur joint arrangement (30 Oct 2025), which pairs this sentence with the US pausing its 29 September 50% penetration rule for one year — an explicitly reciprocal, time-bound exchange. Coded leverage_retaliation on that reciprocity structure. Announcement No. 70 itself contains no justification clause (only 经批准), so the framing anchor is the spokesperson statement, not the instrument text.
为了维护国家安全和利益,履行防扩散等国际义务,加强和规范出口管制,制定本法。EN This Law is enacted for the purposes of safeguarding national security and interest, performing nonproliferation and other international obligations, and strengthening and regulating export control.
Article 1 of the Export Control Law. The Chinese is verbatim from the NPC's Chinese text (src-npc-ecl-2020); the English is the NPC's own official translation, which is why quoteEnSource is "official" and the claim resolves to the English edition. This is the statutory original of the national-security-plus-non-proliferation formula that the later MOFCOM announcements reuse — compare fc-cn-us-ban-natsec, where Announcement No. 46 carries the same two limbs in abbreviated form.
为了维护国家安全和利益,履行防扩散等国际义务,加强和规范两用物项出口管制,根据《中华人民共和国出口管制法》(以下简称出口管制法)等法律,制定本条例。EN These Regulations are formulated in accordance with the Export Control Law of the People's Republic of China (hereinafter the Export Control Law) and other laws, for the purposes of safeguarding national security and interests, performing non-proliferation and other international obligations, and strengthening and regulating export control of dual-use items.
Article 1, verbatim from the State Council's administrative-regulations database. The clause reproduces the Export Control Law's Article 1 purpose formula and adds the subordination to that statute; the translation here is this project's own, rendered to match the NPC's official English of the parent provision where the wording is identical.
为有效保护和合理开发利用稀土资源,促进稀土产业高质量发展,维护生态安全,保障国家资源安全和产业安全,根据有关法律,制定本条例。EN These Regulations are formulated in accordance with the relevant laws in order to effectively protect and rationally develop and utilise rare-earth resources, promote the high-quality development of the rare-earth industry, safeguard ecological security, and ensure national resource security and industrial security.
Article 1 of the Regulations on Rare Earth Administration, verbatim from the State Council portal; translation is this project's own. Three categories are coded because the single sentence carries three distinct limbs — resource protection and ecological security, industrial development, and national resource and industrial security. Worth contrasting with the export-control instruments: this justification is entirely domestic and mentions no foreign state, no non-proliferation obligation and no export.
加强战略矿产资源出口管制事关国家安全和发展利益。EN Strengthening export controls on strategic mineral resources relates to national security and development interests.
Justification clause from the MOFCOM notice's second paragraph, verified verbatim (including punctuation) against the primary. Coded national_security only: the clause pairs security with "development interests" but does not itself elaborate an economic-security or resilience rationale, so no broader category is inferred from it.
为维护国家安全和利益、履行防扩散等国际义务EN to safeguard national security and interests and fulfil international obligations such as non-proliferation
Justification clause of Announcement No. 56 (2025), read verbatim from the MOFCOM primary on 2026-09-23; the same national-security and non-proliferation pairing as Announcement No. 18.
为维护国家安全和利益、履行防扩散等国际义务EN to safeguard national security and interests and fulfil international obligations such as non-proliferation
Justification clause of Announcement No. 57 (2025), read verbatim from the MOFCOM primary on 2026-09-23; the same national-security and non-proliferation pairing as Announcement No. 18.
为维护国家安全和利益、履行防扩散等国际义务EN to safeguard national security and interests and fulfil international obligations such as non-proliferation
Justification clause of Announcement No. 58 (2025), read verbatim from the MOFCOM primary on 2026-09-23; the same national-security and non-proliferation pairing as Announcement No. 18.
为维护国家安全和利益EN to safeguard national security and interests
Justification clause of Announcement No. 62 (2025), read verbatim from the MOFCOM primary on 2026-09-23. Like No. 61 it carries no non-proliferation limb, so only national security is coded.
Events (16)
MOFCOM & GACC Announcement No. 70 of 2025: decision suspending Announcements Nos. 55, 56, 57, 58, 61 and 62 of 2025 (to 10 November 2026)
ActiveMOFCOM Announcement No. 61 of 2025: decision to implement export controls on relevant rare-earth items located outside China
SuspendedMOFCOM & GACC Announcement No. 56 of 2025: decision to implement export controls on certain rare-earth equipment and raw and auxiliary material items
SuspendedMOFCOM & GACC Announcement No. 57 of 2025: decision to implement export controls on certain medium and heavy rare earth items
SuspendedMOFCOM & GACC Announcement No. 58 of 2025: decision to implement export controls on lithium battery and artificial graphite anode material items
SuspendedMOFCOM Announcement No. 62 of 2025: decision to implement export controls on rare-earth-related technologies
SuspendedNational Export Control Coordination Mechanism Office deploys special campaign against smuggling and illegal export of strategic minerals
ActiveMOFCOM & GACC Announcement No. 18 of 2025: export controls on certain medium and heavy rare-earth-related items
ActiveMOFCOM/GACC Announcement No. 10 of 2025 on export controls on tungsten and related items
ActiveMOFCOM Announcement No. 46 of 2024 on strengthening export controls of dual-use items to the United States
ActiveRegulations of the People's Republic of China on Export Control of Dual-Use Items
In forceMOFCOM/GACC Announcement No. 33 of 2024 on export controls on antimony and related items
ActiveRegulations on Rare Earth Administration
In forceMOFCOM/GACC Announcement No. 39 of 2023 on graphite export control measures
ActiveMOFCOM/GACC Announcement No. 23 of 2023 on export controls on gallium- and germanium-related items
ActiveExport Control Law of the People's Republic of China
In forceCapital and control
Financial instruments this actor provides and control clauses it issues.
Control clauses (36)
Open in Controls →Customs enforcement · Customs declaration paragraph
Suspendedto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 56
Export licensing · Item 1 (2B902)
Suspendedto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 56
Export licensing · Item 2 (1C914)
Suspendedto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 56
Customs enforcement · Customs declaration paragraph
Suspendedto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 57
Export licensing · Items 1–5 (1C909–1C913)
Suspendedto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 57
Export licensing · Items 1–2
Suspendedto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 58
Customs enforcement · Customs declaration paragraph
Suspendedto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 58
Export licensing · Item 3
Suspendedto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 58
End-use restriction · Item 1, second paragraph
Suspendedto 10 Nov 2026MOFCOM Announcement No. 62 (2025)
End-use restriction · Item 7
Suspendedto 10 Nov 2026MOFCOM Announcement No. 62 (2025)
Export licensing · Item 1(2) (1E902.b)
Suspendedto 10 Nov 2026MOFCOM Announcement No. 62 (2025)
Export licensing · Item 1(1) (1E902.a)
Suspendedto 10 Nov 2026MOFCOM Announcement No. 62 (2025)
Export licensing · Item 1(1)
In forceMOFCOM/GACC Announcement No. 33 (2024)
Export licensing · Item 1(2)
In forceMOFCOM/GACC Announcement No. 33 (2024)
Customs enforcement
AnnouncedNational Export Control Coordination Mechanism Office deploys special campaign against smuggling and illegal export of strategic minerals
Export licensing · Item 1
In forceMOFCOM/GACC Announcement No. 23 (2023)
Decontrol · Item 2
In forceMOFCOM/GACC Announcement No. 39 (2023)
Export licensing · Item 1
In forceMOFCOM/GACC Announcement No. 39 (2023)
Customs enforcement · Customs declaration paragraph
In forceMOFCOM & GACC Announcement [2025] No. 18
Export licensing · Items 1–7
In forceMOFCOM & GACC Announcement [2025] No. 18
End-use restriction · Item 4
Suspendedto 10 Nov 2026MOFCOM Announcement No. 61 (2025)
Extraterritorial licensing · Item 1(1)
Suspendedto 10 Nov 2026MOFCOM Announcement No. 61 (2025)
Extraterritorial licensing · Item 1(2)
Suspendedto 10 Nov 2026MOFCOM Announcement No. 61 (2025)
End-use restriction · Item 2
Suspendedto 10 Nov 2026MOFCOM Announcement No. 61 (2025)
Extraterritorial licensing · Item 1(3)
Suspendedto 10 Nov 2026MOFCOM Announcement No. 61 (2025)
End-use restriction · Item 3
Suspendedto 10 Nov 2026MOFCOM Announcement No. 61 (2025)
Suspension
In forceto 10 Nov 2026MOFCOM & GACC Announcement [2025] No. 70
Domestic production control · Art. 8
In force国令第785号 (State Council Decree No. 785)
Domestic production control · Art. 13
In force国令第785号 (State Council Decree No. 785)
Domestic production control · Art. 10
In force国令第785号 (State Council Decree No. 785)
Domestic production control · Art. 14
In force国令第785号 (State Council Decree No. 785)
Export licensing · Item 1
In forceMOFCOM/GACC Announcement No. 10 (2025)
Export licensing · Items 2–5
In forceMOFCOM/GACC Announcement No. 10 (2025)
Export prohibition · Item 2, first limb
Suspendedto 27 Nov 2026MOFCOM Announcement No. 46 (2024)
End-use restriction · Item 2, second limb
Suspendedto 27 Nov 2026MOFCOM Announcement No. 46 (2024)
Export prohibition · Item 1
In forceMOFCOM Announcement No. 46 (2024)
