On November 9, 2025, China's Ministry of Commerce officially released Announcement No. 72 of 2025, announcing the suspension of the provisions of Article 2 of Ministry of Commerce 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.
Ministry of Commerce Announcement No. 46 of 2024 was issued and took effect on December 3, 2024. Its 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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