Rare Earth Industry Insights
— Industry News
China Customs' Issues on Export Control of Dual-Use Rare Earth Metals
2025-06-20
On June 16, 2025, the General Administration of Customs of China issued an announcement on matters related to customs challenges to export control of dual-use items. The specific contents are as follows:
1. If the consignor of export goods fails to submit the license issued by the national export control management department to the customs, and the customs has evidence that the export goods may fall within the scope of export control, it shall raise questions to the consignor of the export goods and issue a “Customs Challenge Notice on Export Control of Dual-Use Items”.
2. The consignor of export goods shall submit the following materials as required within 7 working days from the receipt of the “Customs Challenge Notice on Export Control of Dual-Use Items”. The materials shall be stamped with the official seal and be responsible for the authenticity:
(I) Paper customs declaration form;
(II) Export goods contract
(III) Situation description (stating the performance indicators, main uses and reasons for believing that the goods do not fall within the scope of export control, etc.);
(IV) Relevant technical information such as inspection and testing reports;
(V) Other materials required to be submitted by the customs according to regulatory needs.
3. After receiving the materials submitted by the consignor of the export goods, the customs shall make a judgment or propose an organization for identification in accordance with the law, and deal with them in accordance with the law according to the following circumstances, and issue the “Notice of Customs Questioning/Organization Identification Results of Dual-Use Item Export Control”.
(I) If it is determined that there is no need to apply for a dual-use item license, the enterprise shall be notified to handle the subsequent procedures.
(II) If it is determined that a dual-use item license is required, the export goods shall not be released and shall be disposed of in accordance with regulations.
(III) If it is impossible to determine whether it is a dual-use item, an identification application shall be submitted to the national export control management department in accordance with the law, and it shall be handled in accordance with the law based on the identification conclusion.
4. During the identification or questioning period, the customs shall not release the relevant export goods.
Analysis pointed out that this announcement clearly extended the focus of the review to the identification of the dual-use attributes of the items, providing a more operational institutional support for the control of some rare earth metals involving dual-use attributes.
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