China's April 2025 Rare Earth Export Controls: An Eleven Month Historical Sourcing Guide for US Importers

Historical clarification, 10 October 2026: 5 March 2026 was 335 days after 4 April 2025, approximately eleven months rather than one year. This article retains that March perspective. Announcement No. 18 identifies controlled items; it does not establish the article’s approval timelines, rejection statistics, market shares or private experience. Those retained inputs and reported experiences are qualified below. The historical source is not verification of current export rules or a particular shipment’s eligibility.

This guide retains a 5 March 2026 sourcing perspective. MOFCOM Announcement No. 18, issued on 4 April 2025, lists specific samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium related items under control numbers 1C902 to 1C908. It requires exporters of the described controlled items to apply for a licence. The presence of an element or a broad customs heading alone does not establish that every finished product is controlled. The article’s retained 47-business-day first-applicant average, 94% sintered permanent magnet output share and 90% refining share have not been substantiated; they are not verified queue or market measurements. Check the item description, applicable rules and actual exporter before planning a shipment.

What Announcement No. 18 Describes

Announcement No. 18 was issued jointly by MOFCOM and the General Administration of Customs on 4 April 2025. Its control descriptions cover specified metals, alloys, targets, permanent magnet materials, oxides, compounds and mixtures. Read the relevant description and notes against the actual exported goods; the listed customs codes are references. Licensing is not universally limited to individual shipments: at its 18 December 2025 press conference, MOFCOM confirmed approval of some general-licence applications by Chinese exporters. That statement does not establish eligibility for every exporter or foreign customer. The former assertion that there was no challenge route was incorrect: Article 41 of the Export Control Law permits administrative reconsideration of non-approval decisions, with the reconsideration decision final. This historical discussion does not certify an application package or current licensing status.

The article’s account of a late-2025 Busan suspension does not by itself establish which measures applied to a shipment in March 2026 or apply now. For product examples such as magnets, phosphors, master alloys, catalysts and medical materials, distinguish the finished product from the upstream material actually being exported. Match that item to the official control description; do not infer a universal licence requirement for every end-use category or every product containing one of the seven elements.

The retained 47-to-68-business-day PO-to-bill-of-lading range, 90-day first-buyer wait and claimed rise in US-addressed denial rates from 8% to 19% are unverified historical inputs. The earlier attribution to industry association data compiled by Adamas Intelligence has not been substantiated. These figures do not establish an observed queue, denial trend or delivery timetable; obtain an actual exporter and application status before committing to a date.

The element-by-element status table you should have open in every sourcing meeting

The table retains unverified historical market shares, supplier availability and project-stage claims. Its broad HS headings and end-use examples are screening prompts, not an authoritative control list or proof of licence eligibility. Confirm the actual item description and supplier capability before relying on a row.

The table’s retained 99% terbium and dysprosium shares and 68% scandium share are not substantiated measurements. They do not prove that a particular separation or metallisation route must pass through China, that a named company can supply the required material, or that scandium is the only element with a commercially operable alternative. Establish the actual production route, qualification, available capacity and origin through supplier records and quotations.

Preparing a MOFCOM Export Licence Application

The article reports seeing applications take 32 and 110 days. That private experience has not been independently substantiated, and the suggested link between documentation quality and those timings is not demonstrated. It does not establish a 90-day queue, an approval deadline or a guarantee that improving a package will secure approval. Ask the exporter to confirm the applicable application requirements and actual status.

For a planning discussion with the exporter, consider recording the corporate identity and authorised contact, intended application and consuming site, expected quantity, relevant end-user or end-use statements, and requested supporting evidence. These are suggested preparation topics, not verified minimum statutory elements. The historical article’s HS-8 requirement, particular non-diversion wording, consent clause and mandatory audit within 12 months have not been established by the cited announcement. Use the applicable official forms and requirements; do not treat this checklist as an accepted certificate.

Describe the proposed downstream use clearly. The retained Greenville, South Carolina catalyst example, including its HS 3815.12 reference and 18-tonne quantity, illustrates a proposed description; it is not verified classification or wording approved by MOFCOM. The article’s claim that generic industrial wording will automatically be rejected is not substantiated. Confirm any requested corporate, site or customer documents with the exporter and the applicable authority.

Review the actual end user, end use and applicable restrictions with the exporter. The historical article’s asserted connection to US or Chinese lists does not establish that any defence-prime relationship automatically causes denial or a longer queue. Neither approval nor rejection can be inferred from that label alone; assess the applicable rules and the actual application without guaranteeing an outcome.

The landed-cost arithmetic on a dysprosium-iron master alloy in March 2026

The private example below has not been independently substantiated, and its former duty comparison was based on an inappropriate tariff heading. Client wanted 12 tonnes of dysprosium-iron master alloy at 80% Dy, for use in high-coercivity neodymium iron boron magnets produced at their Ohio site.

Chinese route. FOB Ningbo-Zhoushan in early March 2026 was $412 per kilogram of contained Dy, plus the iron carrier. All-in per tonne of alloy, roughly $348,000. Ocean freight to LA/Long Beach under class 4.1 hazmat rules on a dedicated isotainer, $4,200 per tonne. Heading 8105.20 covers cobalt products in USITC’s February 2026 tariff schedule; it does not substantiate the described dysprosium-iron classification. The stated duty stack and $488,000 landed total are withdrawn as a verified calculation. Actual classification, origin, customs value and entry date require review. Licence-queue-adjusted lead time, 68 business days from PO to vessel departure.

Ex-China route via Lynas Kalgoorlie toll separation with metallisation in Estonia at Silmet. FOB Fremantle at $468,000 per tonne of alloy. Ocean freight Fremantle to Seattle direct, $3,800 per tonne. The claimed 5.5% duty, absence of other tariff layers and $498,000 landed total have not been verified. Lead time, 34 business days. The dependent $10,000 or 2% premium is therefore not established. The quoted lead times and risk reduction remain unverified private assumptions.

The example does not establish that a 2% premium eliminates licensing risk or that the Chinese route wins on price. A comparison needs verified quotations, correct duty treatment and the actual supply-chain and licensing facts.

Four moves to make this month

First, screen the purchase orders relevant to your sourcing programme for possible Announcement No. 18 exposure. An element, CAS reference or broad HS heading can prompt review, but does not decide control status. Compare the actual exported item with the official control description and notes, and document what still needs clarification.

Second, investigate a suitable alternative source for a material exposure. The table’s named suppliers, NDA requirements and six-to-fourteen-month lead-time range are unverified historical planning inputs. Confirm the actual material, qualification process, available capacity and quotation; a company name does not establish that it can supply your product.

Third, review the application and end-user documents held by the exporter against the requirements applicable to the actual transaction. Their drafting date alone does not establish that re-certification is required. Confirm any requested update and its basis before treating it as mandatory.

Fourth, test the sensitivity of your budget to actual quotations and uncertain licensing or delivery costs. The retained 15-to-25% uplift above a 2024 baseline is an unverified historical scenario, not a demonstrated 2026 price floor for all seven elements. It does not establish which costs will persist or what a supplier will charge.

At the preserved 5 March 2026 perspective, Announcement No. 18 was approximately eleven months old. The historical announcement does not establish that its rules will remain unchanged for another year, that the reported Busan account decides a particular shipment, or that one sourcing forecast will outperform another. Verify the measures and transaction facts applicable when making a decision.