Controlled strategic materials · 09 Editorial guide
China Export Controls for Strategic and Critical Materials
Current controls affecting rare earths, gallium, germanium, graphite, antimony and tungsten.
First job Identify the exact material, form and specifications before checking the current official notice.
Direct answer
What this page decides
01
Strategic-material controls are notice- and specification-dependent. A commodity name alone does not establish whether a shipment is controlled. Identify composition, purity, form and technical characteristics, then check the current MOFCOM and GACC instruments and licence position for the shipment date.
At a glance
Which fact changes the next route
Use the fact that changes ownership or urgency to decide the next move.
| Question | Why it matters | Next route |
|---|---|---|
| Commodity name matches an announcement? | Coverage usually turns on a defined form or specification. | Compare laboratory and product data with the current text. |
| Control recently changed? | Temporary and date-specific measures can change the answer. | Create a dated legal-source record before shipment. |
Scope
What this page owns — and what it does not
Practical workflow
Action, evidence, legal gate, output
| Action | Documents / evidence | Legal gate | Output |
|---|---|---|---|
| Identify the material precisely | Composition, purity, form, grade, technical sheet | Controlled specification | Material identity file |
| Check current official measures | MOFCOM/GACC notices and catalogues | Effective date and scope | Dated legal check |
| Complete transaction review | End user, end use, destination, contract | Licence and catch-all | Ship, license or stop decision |
Documents
What to gather before the next call
These items help clarify the file; they are not a legal requirement list.
| Item | Why needed | Who holds it | Risk if missing |
|---|---|---|---|
| Laboratory certificate and specification | Coverage analysis | Engineering or quality | Generic commodity label |
| Official-notice and licence record | Shipment-date evidence | Trade compliance | Stale list |
Common failure points
Where files usually break
Assuming every form of a named material is controlled.
Relying on last year’s catalogue for a current shipment.
FAQ
Narrow follow-ups owned by this page
Can the commercial invoice decide coverage?
No. Legal coverage depends on the current control text and the material’s actual characteristics.
Quick answers
Need the short version? Start with one narrow question.
These explainers answer one question. They do not replace this topic route or a deep guide.
Curated resources
Open the asset that matches this job.
Counsel hand-off
What to bring when you instruct
Instruct export-control counsel where the specification boundary or current notice is unclear. Bring test data, product sheets, parties and shipment date.
Local context
Add the port when local customs practice changes.
Clearance, bonded and audit practice can differ by port and FTZ after the national question is identified.
Open city and province guidesCounsel hand-off
Need trade and customs counsel?
This hub organises classification, value, clearance and clocks. It does not declare goods, compute duty or bind Customs on your facts.
Find trade & customs counselLegal review
Who reviewed this guide
Need qualified counsel?
Move carefully. Move with a record.
Use the portal to identify counsel for this practice and related China-side issues.