China Customs on Dual-Use Rare Earth Export Control

2025-06-20

Overview

On June 16, 2025, the General Administration of Customs of China released new guidance on handling export control challenges related to dual-use items, including certain rare earth metals. The announcement strengthens procedural clarity and enforcement at the customs level.

Customs Review Trigger Mechanism

When exporters fail to submit a valid dual-use export license and customs authorities have reasonable grounds to believe the goods fall under export control, a Customs Challenge Notice will be issued.

Exporter Response Requirements

Required Submission Timeline

Exporters must respond within seven working days after receiving the challenge notice.

Required Documentation

The following documents must be submitted with official company seals:

Paper customs declaration form
Export contract
Situation statement (performance indicators, intended use, justification)
Technical documents (inspection or testing reports)
Other materials requested by customs

Customs Determination Outcomes

No License Required

Goods may proceed with standard export clearance.

License Required

Export clearance will be denied, and goods will be handled under export control regulations.

Dual-Use Status Unclear

Customs will request formal identification from the national export control authority.

During all review and identification stages, goods will not be released.

Implications for Rare Earth Exports

The announcement shifts regulatory focus toward operational identification of dual-use attributes, increasing compliance pressure on rare earth exporters and improving enforcement consistency.

Conclusion

China Customs’ updated procedures reinforce stricter oversight of dual-use rare earth exports. Exporters should enhance documentation readiness and compliance systems to adapt to tighter regulatory scrutiny and reduce clearance risks.

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