For buyers of electronics, permanent magnets, or any product incorporating rare earth materials, China’s export licensing regime has moved through several phases since 2025. Here’s a neutral rundown of what’s currently in force, what’s currently suspended, and — critically — what the licensing process actually looks like from the Chinese magnet manufacturer’s side, not just the policy summary.
The Core Framework: Still Active
In April 2025, China’s Ministry of Commerce (MOFCOM), together with the General Administration of Customs, introduced licensing requirements for seven medium and heavy rare earth elements — including dysprosium, terbium, and samarium — plus related products such as samarium-cobalt and dysprosium/terbium-bearing NdFeB magnets. This requirement has remained continuously in place since April 2025. China accounts for roughly 90% of global rare earth refining capacity, which is why this licensing system has outsized supply chain effects.
What “General License” Actually Looks Like on the Ground
Throughout 2025, the operative process was case-by-case (逐笔审批): every shipment required its own individual license application, with a stated processing window of up to 45 working days and a requirement to disclose detailed end-user information — a process Chinese industry commentary consistently described as a significant bottleneck on export efficiency.
That changed in December 2025, when China issued its first batch of General Licenses — a mechanism new enough that, as of this writing, only a handful of companies hold one. Reuters and Chinese financial media identified the first recipients by name: JL MAG (金力永磁), Ningbo Yunsheng (宁波韵升), and Zhongke Sanhuan (中科三环). What’s worth understanding is that a General License isn’t a blanket clearance for a company’s entire product line — it’s scoped to specific downstream customers. Industry reporting indicates JL MAG’s approved scope reportedly covers nearly all of its customer base, while Ningbo Yunsheng and Zhongke Sanhuan’s approved scope is considerably narrower, limited to a subset of their partner customers. Two companies holding the same category of license can have meaningfully different practical export capacity.
A detail worth flagging for buyers specifically: the approval gate sits substantially on the downstream end-customer, not just the Chinese magnet producer. Per MOFCOM’s stated requirements, the end-customer must submit documentation demonstrating the magnets are destined for civilian applications — humanoid robotics and automotive use cases are specifically cited — and are not at risk of diversion to military use or resale. In practice, this means a foreign buyer may need to participate directly in the documentation process, not simply wait for a supplier to produce a license.
The Extraterritorial Trigger, Precisely
Legal analysis from Chinese law firm AllBright (锦天城), examining MOFCOM Announcement No. 61 of 2025, identifies three distinct, independent conditions that trigger the licensing requirement for a product manufactured entirely outside China:
- The foreign-made rare earth material (magnets or sputtering targets) contains Chinese-origin rare earth substances — among a specified list of thirteen, including samarium metal, samarium-cobalt alloy, and dysprosium oxide — at 0.1% or more of the material’s value; or
- The foreign-made product was manufactured using Chinese-origin rare earth technology — covering extraction, smelting/separation, metal refining, magnet manufacturing, or secondary resource recovery techniques; or
- The rare earth material or substance itself originates in China.
Any one of these three conditions independently triggers the requirement — they aren’t cumulative. This precision matters for buyers assessing exposure: a product could trigger the rule through inherited manufacturing know-how even where the physical material content falls under the 0.1% value threshold.
What’s Currently Suspended — and When That Changes
In October 2025, China announced an expansion of controls along with these extraterritorial provisions. Following an October 2025 diplomatic de-escalation, China suspended the October expansion measures — that suspension is set to expire around November 10, 2026. A separate measure covering dual-use items (gallium, germanium, antimony, graphite, superhard materials) was suspended under a different announcement, running until November 27, 2026 — two distinct suspensions with two distinct expiration dates.
What Remains Explicit and Unchanged
MOFCOM has maintained that export applications will not be approved where the end-user is an overseas military entity, and that advanced-semiconductor-related applications are handled case-by-case rather than through general licensing.
What This Means for Sourcing Decisions
- Don’t treat “our supplier has a General License” as sufficient — ask whether your specific company is within the license’s approved customer scope, given that scope varies significantly between license holders.
- Be prepared to provide end-use documentation yourself; the civilian-use justification burden sits partly with the buyer, not solely the Chinese exporter.
- For products assembled outside China, check exposure against all three extraterritorial trigger conditions — material content, inherited technology, and material origin — not just a simple “contains Chinese material” test.
- Build in lead-time buffers regardless of license type; even General License holders operate within a system where processing history has skewed toward delay.