At a glance — regulatory timeline

When Measure
2024-12-01 Regulations on Export Control of Dual-Use Items take effect — scattered controls consolidated into one system and unified list
2025-02-04 Controls begin on 41 HS codes covering tungsten, tellurium, bismuth, molybdenum, and indium
2025-04 Seven heavy rare earths added (samarium, gadolinium, terbium, dysprosium, lutetium, scandium, yttrium)
2025-10-09 Six announcements: five more rare earths, lithium-battery and synthetic-graphite anode materials, superhard materials, and a 0.1% extraterritorial rule
2025-11-07 Under the US-China agreement, those six October announcements suspended for one year, until 2026-11-10 (Announcement No. 70)
2026-01-06 Blanket ban on dual-use exports to Japanese military end-users and uses (Announcement No. 1 of 2026)
2026 catalog About 70 items added — seven heavy-rare-earth codes, tungsten-nickel alloys, specific molybdenum powders, indium, bismuth, tellurium

What is in force now

Controls on gallium, germanium, antimony, and graphite (since 2023), the tungsten/molybdenum group (February 2025), seven heavy rare earths (April 2025), and the blanket ban on Japanese military uses (January 2026) are all currently in force. Chinese exporters need case-by-case licenses for these items; the nominal review period is 45 days, but longer processing is consistently reported.

What is suspended — November 10 is the inflection point

The October 9, 2025 expansion (five more rare earths, battery materials, superhard materials, the 0.1% extraterritorial rule) is suspended only until November 10, 2026 under the US-China leaders' agreement. No extension has been decided, and the measures could snap back within Q4. If the extraterritorial rule revives in particular, third-country processed goods containing as little as 0.1% Chinese-origin material could fall under control — extending the impact well beyond direct raw-material imports.

A change in how controls operate — from licensing to designated exporters

Tungsten and antimony have moved beyond case-by-case licensing to a designated-exporter (state trading) system. For 2026–2027, only 15 companies may export tungsten and 11 may export antimony, and there is no external application path onto the list. The procurement question is no longer "do you have a supplier" but "does your supplier have export qualification."

What changes directly for powder buyers

The 2026 control catalog newly lists tungsten-nickel alloys and specific molybdenum powders. In metal-powder and AM-powder procurement, the same product name can be controlled or not depending on alloy composition and purity — check against the 10-digit HS code at the quotation stage.

Note for procurement teams

  • Settle controlled/non-controlled status at the quotation stage, by 10-digit HS code. The same product name can go either way depending on composition and purity.
  • Controlled items require end-use and end-user statements (EUS). Preparing documents in advance shortens review delays.
  • Now is the time to weigh securing Q4 volumes before the November 10 expiry. If the measures snap back, license lead time becomes a bigger variable than price.
  • TKNCO checks controlled status for the items we handle and source, and supports the licensing paperwork. Send a product name or CAS number and we reply within 48 hours with sourcing feasibility.

This brief summarizes the public sources below for general information and is not legal advice. Controlled status for individual transactions requires customs and legal confirmation.

References