On Thursday, October 9, 2025, China issued a series of new export control measures and designations on China’s Unreliable Entity List (UEL).

The new controls significantly expand the scope of China’s oversight over its rare earth materials by comprehensively regulating the entire supply chain of Chinese-origin rare earths, from specified raw materials to mining and manufacturing technologies, production equipment, and downstream products. Announcement No. 61 is especially significant because it broadens China’s extraterritorial jurisdiction to the re-export of goods. It also introduced its versions of de minimis rule and the Foreign Direct Product Rule (FDPR), by regulating foreign-made products that contain a de minimis amount of Chinese rare earths content or manufactured with Chinese rare earths technologies.

The 14 newly designated parties added to the UEL primarily include U.S. firms in the defense and intelligence sectors and entities linked to Taiwan’s defense sector.

Below is a summary of key provisions in the series of announcements:

1. Export Controls on Rare Earths: A Dual Prong Approach

China’s exports controls on rare earth metals and permanent magnets date back to April 4, 2025.

Announcement No. 61 further expands such exports controls extraterritorially by regulating the export of the following items by foreign entities or individuals to third countries, no longer limited to direct exports from China:

• Chinese-origin rare earths listed in Annex 1 of the Announcement No. 61 (re-export);
• Foreign-made permanent magnet materials and target materials listed in Part 2 of Annex 1, that contain, are integrated or commingled with Chinese-origin rare earth metals listed in Part 1 of Annex 1 where the Chinese content value reaches 0.1% or more (de minimis rule); and
• Foreign-made items listed in Annex 1 that are manufactured using Chinese rare earth mining, separation, smelting, magnet manufacturing, or recycling technology (FDPR).

This announcement is China’s first application of the re-export, de minimis rule and FDPR rules that have been largely used by the U.S. to regulate semiconductor exports. Most of the export control requirements in Announcement No. 61 are effective December 1, 2025, except for controls on the re-export of Chinese-origin rare earth materials, which are effective immediately.

Additionally, Announcements Nos. 56, 57 and 62 introduce comprehensive controls on the entire rare earths supply chain—from raw materials and new rare earth elements, manufacturing equipment, and mining and manufacturing technologies. Announcement No. 56 imposes export controls on certain rare earth equipment and raw/auxiliary materials. Announcement No. 57 adds five new rare earth elements to China’s export controls measures: holmium, erbium, thulium, europium, and ytterbium. These controls are effective November 8, 2025. Finally, Announcement No. 62 imposes export controls on technologies related to rare earth mining, smelting and separation, metal refining, magnetic material manufacturing, recycling, and related production line assembly, calibration, maintenance repair, and upgrading technologies.

Combined, these announcements regulate the export and re-export of any products that directly or indirectly contain Chinese-origin rare earth materials and technologies at any point in their supply chain. These controls severely limit the use of Chinese-origin rare earths materials and technologies in any foreign defense supply chains and military end use applications.

2. Export Controls on Other Strategic Materials

In addition to expanded controls on rare earths, China also introduced controls on other strategic materials. Announcement No. 55, imposes export controls on superhard materials, including specific synthetic diamond powders, single crystals, ultra-thin diamond wire saws, high-speed grinding wheels, and related production equipment and technology. Announcement No. 58 imposes export controls on dual-use products related to lithium batteries and synthetic graphite anode materials, including high-performance batteries and their manufacturing equipment and technology. Both announcements are effective November 8, 2025.

3. New Designations on the Unreliable Entity List

Lastly, China announced the addition of14 entities to China’s Unreliable Entity List (UEL). These entities are mostly U.S.-based and in the defense and intelligence sectors. Effective October 9, 2025, these entities are prohibited from making new investments in China and engaging in import and export activities related to China. Any transactions and the transfer of data and information between these entities and persons/organizations in China are also prohibited.

Given that China leads the production of rare earths minerals globally, accounting for 70% of the world’s supply and 90% of global rare earth ore processing, China’s tightening of export controls on rare minerals and other strategic materials will have far-reaching effects on high-tech industries and supply chains. The impacted industries include defense (including products such as jet fighters, drones, and nuclear submarines), renewable energy (wind turbine generators and energy storage systems), electric vehicles, semiconductors, and consumer electronics.

For additional questions and guidance, please contact Crowell’s Export Controls Practice.