Chinese graphite and antimony export controls (2023-present)

China's graphite and antimony export controls placed selected forms of two strategically important materials under licensing from December 2023 and September 2024. A separate December 2024 measure prohibited dual-use exports to United States military users or for military use, established a presumption against licensing specified materials to the United States, and tightened review of graphite dual-use exports to that destination. In November 2025, China suspended the latter licensing and graphite-review provisions until 27 November 2026. The military-user and military-use prohibition was outside that suspension.

Legal sequence

Announcement No. 39 of 2023 placed selected natural and synthetic graphite items under export control from 1 December 2023. Exporters had to apply for licences and provide information about products, end users and end use. It was a licensing regime, not a general ban.

Announcement No. 33 of 2024 applied controls to specified antimony ores, metals, compounds, processing equipment and related technology from 15 September 2024. Product coverage followed the annex. Broad references to antimony exports overstate the legal scope.

Announcement No. 46 of 2024 added a destination-specific layer. Paragraph 1 prohibited dual-use exports to United States military users or for military use. Paragraph 2 stated that exports to the United States of listed gallium, germanium, antimony and superhard-material dual-use items would, in principle, not be licensed, while graphite dual-use exports would receive stricter end-user and end-use review. Announcement No. 72 of 2025, dated 9 November 2025, suspended only paragraph 2 from that date through 27 November 2026. It did not suspend paragraph 1 or abolish other applicable product controls. Any description of current law must check these notices and subsequent amendments separately.

Purpose and market effects

The Ministry of Commerce framed the controls as national-security and non-proliferation measures. Their timing amid United States semiconductor restrictions supports an inference of strategic signalling, but the official rationale and inferred retaliatory purpose must remain distinct.

Licensing can delay shipments, reveal end-use information and permit selective denial without ending all trade. Market effects depend on approvals, inventories, product grade, processing capacity and demand. A price change in one antimony or graphite benchmark cannot be assigned to policy without controlling for mine supply, restocking and downstream consumption.

The controls also encouraged importers to reassess concentration risk. Investment announcements in alternative mines or processing plants show policy response only when the investor identifies the controls as a material cause. Announcements do not prove that new capacity became commercially available.

Assessment

This is a main-sequence case of resource and supply-chain statecraft. China used legal control over exports from a concentrated production and processing base to create approval risk and potential denial. The intervention combined product licensing, destination-specific licensing restrictions and a military-user and military-use prohibition.

The case demonstrates why legal precision is strategic analysis. A licence requirement, a denial, a customs delay and a suspended prohibition impose different levels of pressure. Current status must be checked against Ministry of Commerce notices on the day of publication.

See also

Critical minerals weaponisation · China's gallium and germanium export-control campaign (2023-present) · Rare-earth and critical-mineral export restriction · Technology denial · Strategic stockpiling

Sources

1. Ministry of Commerce and General Administration of Customs of China, 'Announcement No. 39 of 2023', graphite controls.
2. Ministry of Commerce of China, 'Regular Press Conference, January 2024', graphite licensing.
3. Ministry of Commerce and General Administration of Customs of China, 'Announcement No. 33 of 2024', antimony controls.
4. Ministry of Commerce of China, 'Regular Press Conference, August 2024', antimony controls.
5. Ministry of Commerce of China, 'Announcement No. 46 of 2024', 3 December 2024, paragraphs 1 and 2. Official Chinese text; English account is a translation.
6. Ministry of Commerce of China, 'Announcement No. 72 of 2025', 9 November 2025.
7. United States Geological Survey, Mineral Commodity Summaries 2026, graphite and antimony chapters.
8. General Administration of Customs of China, Customs Statistics, commodity-level export data.