Mainrich International
Market Update3 min readApril 21, 2026· Updated Oct 11, 2026

China Rare Earth Export Controls: Item Classification and MOFCOM Licensing

Review the actual magnet or assembly, composition, exporter, parties and end use. A grade name does not determine the licensing outcome.

Mainrich International

Mainrich International

Engineering Team

rare earth export controls 2026MOFCOM export licenseNdFeB export controlsChina magnet exportdysprosium terbium licenserare earth supply chainmagnet procurement 2026neodymium magnet import

Key Takeaways

  • ◆Announcement 18 and the suspended October 2025 measures have different scopes.
  • ◆Neither a suffix nor an F-Series label establishes composition or clearance.
  • ◆Specified deeply processed rotor/stator assemblies are generally outside Announcement 18 under MOFCOM guidance; that is not a blanket assembly exemption.
  • ◆The 45-working-day rule is a decision period after acceptance with exceptions and excluded time.
  • ◆Single and general licences have different conditions. Confirm the authorization that covers the proposed export.
01

Identify the item

Announcement 18 of 4 April 2025 lists specified rare-earth items, including SmCo permanent-magnet materials and NdFeB permanent-magnet materials containing Tb or Dy. The notice does not establish a generic combined Dy+Tb ≤0.1 wt% safe harbour. Trace content and uncertain items require classification; a grade suffix cannot decide the outcome.

Key insight

Reviewed 12 September 2026. This article retains its original publication date. The linked rules have the source dates stated below; confirm the instruments in force for the intended entry or shipment date.

02

Distinguish a magnet from a processed assembly

MOFCOM’s 16 September 2025 FAQ says the described rotor/stator components with magnets fixed into or onto iron cores or steel plates, including specified more integrated constructions, are generally outside Announcement 18. This qualified guidance does not clear every assembly or remove other applicable controls.

03

What the suspension covers

Announcement 70 of 7 November 2025 suspends Announcements 55–58 and 61–62 until 10 November 2026. On 28 September 2026 a MOFCOM official said the arrangement behind that suspension is extended to 10 January 2027 (statement); as of 11 October 2026 no announcement changing that date had been published.

Announcement 18 is absent from that suspension list. The suspension is not a shipment deadline or a blanket exemption. Check subsequent notices for the intended shipment date.

04

Understand the review period

Decree 792, Article 17 provides for an approval or refusal decision within 45 working days after acceptance, with exceptions and excluded assessment, expert-consultation and verification time. This is not a fixed duration, a minimum wait or a guaranteed shipment date.

Articles 15 and 18 distinguish single and general licences and require exports to stay within the authorization’s scope, conditions and validity.

05

Identify the responsible exporter

Articles 14 and 16 of Decree 792 place the application responsibility on the exporter. Confirm the legal exporter, contracting supplier and manufacturing entity separately. Factory ownership, an overseas office or a commercial label does not establish authorization.

Article 24 provides for end-user and end-use evidence; it does not create a universal importer approval for every EU or US magnet buyer.

06

Prepare the order records

Agree the product description, composition evidence, technical specification, parties, destination, end user and end use before applying. Check the applicable party restrictions and route. Document changes that may affect authorization. Production planning and document preparation may run alongside each other, but neither guarantees approval or customs release.

07

What Mainrich can review

Send the drawing and intended commercial use so that Mainrich can review the proposed supply route and documentation with the exporter. Mainrich’s sintered NdFeB range is N30 to N56, with no AH grades. The top grade depends on the temperature series: N56, N54M, N52H, N52SH, N50UH and N45EH. Grades up to N52SH can be made without a Chinese export licence, so we offer those first; UH and EH grades need a licence, applied for per order.

Confirm the grade, suffix, geometry and production route for each drawing. This summary does not offer every combination; grades outside it in educational examples are not Mainrich supply offers. Check the current certificate for the actual manufacturing entity, address and activity. Agree PPAP level and required reports for the order; a network relationship does not certify every plant or assembly. Release remains conditional on the required approvals.

FAQ

Frequently Asked Questions

Does my grade require a licence?

+

Announcement 18 of 4 April 2025 lists specified rare-earth items, including SmCo permanent-magnet materials and NdFeB permanent-magnet materials containing Tb or Dy. The notice does not establish a generic combined Dy+Tb ≤0.1 wt% safe harbour. Trace content and uncertain items require classification; a grade suffix cannot decide the outcome.

Are all magnet assemblies controlled?

+

MOFCOM’s 16 September 2025 FAQ says the described rotor/stator components with magnets fixed into or onto iron cores or steel plates, including specified more integrated constructions, are generally outside Announcement 18. This qualified guidance does not clear every assembly or remove other applicable controls.

Is every application a fixed 45-working-day wait?

+

Decree 792, Article 17 provides for an approval or refusal decision within 45 working days after acceptance, with exceptions and excluded assessment, expert-consultation and verification time. This is not a fixed duration, a minimum wait or a guaranteed shipment date. Articles 15 and 18 distinguish single and general licences and require exports to stay within the authorization’s scope, conditions and validity.

Does every shipment need a new application?

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The applicable single or general licence determines the permitted exports. General-licence eligibility and coverage are conditional; confirm the scope, parties and validity with the exporter.

Do F-Series, Ho substitution or GBD establish clearance?

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Grade suffixes and F/N/D series labels do not establish composition or export clearance. Classify the actual item and transaction with the exporter, including the parties, end use and route. See the export-control guide.

Does the suspension remove Announcement 18?

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Announcement 70 of 7 November 2025 suspends Announcements 55–58 and 61–62 until 10 November 2026. On 28 September 2026 a MOFCOM official said the arrangement behind that suspension is extended to 10 January 2027 (statement); as of 11 October 2026 no announcement changing that date had been published. Announcement 18 is absent from that suspension list. The suspension is not a shipment deadline or a blanket exemption. Check subsequent notices for the intended shipment date.

Send the drawing, destination, end user and intended use for an initial supply review. Shipment timing depends on the required authorization and production plan.

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