China Eases U.S. Export Controls on Gallium, Germanium, Ultra-Hard Materials, Graphite, and Other Dual-Use Items

On November 9, 2025, China's Ministry of Commerce (MOFCOM) officially released Announcement No. 72 of 2025, announcing the suspension of the provisions of Article 2 of MOFCOM  Announcement No. 46 of 2024 (Announcement on Strengthening Export Controls on Certain Dual-Use Items to the United States), effective immediately until November 27, 2026.

The MOFCOM Announcement was issued and took effect on December 3, 2024. Article 2 stipulated the following:

In accordance with laws and regulations, including the Export Control Law of the People's Republic of China, and to safeguard national security and interests and fulfill international non-proliferation obligations, it was decided to strengthen export controls on certain dual-use items to the United States. In principle, exports to the U.S. of dual-use items related to gallium, germanium, antimony, and ultra-hard materials were not permitted; stricter end-user and end-use reviews were implemented for exports of dual-use graphite items to the U.S.

The provisions of Article 1 in the aforementioned announcement, which prohibit the export of dual-use items to U.S. military end-users or for military end-uses, remain in full effect. Enterprises must continue to strictly comply, and violations will be pursued in accordance with the law.

This temporary adjustment of specific provisions will provide a policy window for relevant enterprises exporting to the United States. Enterprises involved in the export of items such as gallium, germanium, antimony, ultra-hard materials, and graphite should closely monitor policy developments, strategically arrange their U.S. export activities, and continue to adhere to the export ban for military purposes to mitigate trade risks.

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