Graphite processing, anode materials and export controls

Graphite processing, anode materials and export controls concern distinct stages of a concentrated battery supply chain. Chinese authorities apply dual-use licensing and end-use review to defined graphite products, while other governments finance diversification. The statecraft lies in those legal and industrial-policy actions, not in China's market share alone. A licence requirement permits screening and possible delay, conditioning or denial. It is not a general embargo.

Materials and processing stages

Natural graphite is mined as ore and concentrate. Battery use then requires purification, micronisation, shaping or spheronisation, and often coating. Synthetic graphite is manufactured from carbon feedstocks through a separate energy-intensive process. Active anode material is the processed product ready for cell manufacture. Mine output, purified spherical graphite, synthetic graphite and finished anode material therefore require separate denominators.

The International Energy Agency's 2026 risk analysis placed China's share of battery-grade graphite refining above 90 per cent under a definition combining relevant natural and synthetic battery-grade supply. That concentration indicates exposure, but it does not establish direct state control of every processor or a realised disruption. Most current lithium-ion cells use graphite-rich anodes, while blends, alternative materials, recycling and new chemistries affect substitution over time.

Chinese legal sequence

Announcement No. 39 of 2023 subjected specified natural flake graphite products and high-purity, high-strength, high-density synthetic graphite products to export licensing from 1 December 2023. Announcement No. 51 of 2024 incorporated these high-sensitivity items into China's unified dual-use export-control list from 1 December 2024. The earlier stand-alone announcement was repealed, but the listed items were not decontrolled.

Product coverage turns on the listed specifications and customs classification, not on the generic label graphite. Licence outcomes must therefore be traced to the exact item, exporter, end user and end use.

Announcement No. 46 of 2024 introduced stricter end-user and end-use review for relevant exports to the United States. Announcement No. 72 of 2025 suspended its second clause until 27 November 2026. The general unified-list licence requirement remains separate and operative.

Announcement No. 58 of 2025 would add specified lithium batteries, cathode materials, graphite anode materials, production equipment and technologies. Announcement No. 70 of 2025 suspended that measure to 10 November 2026. On 9 November 2026, MOFCOM and the General Administration of Customs issued Announcement No. 58 of 2026, specifying that the suspension of 2025 announcements 55, 56, 57, 58, 61 and 62 would continue from 11 November 2026 to 10 January 2027. At this 10 November check, the specified start date remains in the future. The continuation concerns the named measures; its list does not include Announcement No. 18 of 2025 and does not remove every export-control requirement.

Roles, effects and resilience

The state nexus is direct for export-control law and public diversification policy. Chinese ministries and customs authorities administer the licence regime; miners, processors, traders, importers and battery manufacturers transmit its effects. State-owned, private and mixed firms must remain distinct. Responding governments may use subsidies, finance, procurement, stockpiles or standards to build alternative capacity.

Legal scope does not demonstrate effectiveness. Assessment requires product-level applications, approvals, conditions, delays, denials, customs flows, inventories, prices and production. New mines also do not supply qualified anode material without purification, equipment, power, environmental approval and customer qualification. Diversification is consequently slower and more capital-intensive than a raw resource comparison suggests.

See also

Lithium, cobalt and nickel refining and downstreaming · Critical-mineral export controls · Battery supply chains · Supply-chain resilience

Sources

1. Ministry of Commerce and General Administration of Customs of the People's Republic of China, "Announcement No. 39 of 2023 on Optimising and Adjusting Temporary Export Controls on Graphite Items", 20 October 2023.
2. Ministry of Commerce, Ministry of Industry and Information Technology, General Administration of Customs and State Cryptography Administration of the People's Republic of China, Unified Dual-Use Items Export Control List and Repealed Announcements, Announcement No. 51 of 2024.
3. State Council of the People's Republic of China, "Regulations on Export Control of Dual-Use Items", State Council Order No. 792, 30 September 2024.
4. Ministry of Commerce of the People's Republic of China, "Announcement No. 46 of 2024 on Strengthening Export Controls on Certain Dual-Use Items to the United States", 3 December 2024.
5. Ministry of Commerce of the People's Republic of China, "Announcement No. 72 of 2025 Adjusting Implementation of Announcement No. 46 of 2024", 9 November 2025.
6. Ministry of Commerce and General Administration of Customs of the People's Republic of China, "Announcement No. 58 of 2025 on Lithium Batteries and Synthetic Graphite Anode Materials", 9 October 2025.
7. Ministry of Commerce and General Administration of Customs of the People's Republic of China, "Announcement No. 70 of 2025 Suspending Announcements Including No. 58", 7 November 2025.
8. International Energy Agency, Global Critical Minerals Outlook 2026: Outlook (2026).
9. International Energy Agency, Global Critical Minerals Outlook 2026: Executive Summary (2026).
10. United States Geological Survey, Mineral Commodity Summaries 2026, version 1.3, May 2026.
11. Ministry of Commerce and General Administration of Customs of the People's Republic of China, Announcement No. 58 of 2026 continuing the suspension of specified 2025 announcements, 9 November 2026; specified period 11 November 2026 to 10 January 2027. Complete Chinese text, accessed 10 November 2026.