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Items covered under Announcement No. 33 of 2023:
graphite and graphite powder used in battery anodes, expanded graphite, and graphite foil products.
high-hardness (Shore hardness >70), and high-strength (tensile strength >50 MPa) materials used in anode production, EDM electrodes, and semiconductor crucibles.
Mechanism is licensing, not an outright ban. Exporters must file applications with MOFCOM citing end-user, end-use, and ultimate destination. Licences are reviewed on dual-use and national-security grounds. Unlike the Ga/Ge regime (which saw near-zero approvals in the first two months), graphite licences were processed with shorter delays, consistent with China's interest in maintaining EV supply-chain relationships with European and Korean battery makers while signalling escalation capacity.
China accounts for approximately 65-70% of global natural graphite mine output and over 90% of the spherical graphite and artificial graphite anode material used in lithium-ion batteries globally (USGS Mineral Commodity Summaries 2023-24). There is no short-run substitute for graphite in the dominant lithium-ion anode chemistry; silicon-anode alternatives remain sub-10% of production.
Severity is set at 4 rather than 5 because: (a) The measure is a licence requirement, not a ban; approval rates for non-US destinations have been meaningful. (b) South Korea, Japan, and North American producers have accelerated domestic graphite and synthetic-anode investment (Novonix, Syrah Resources, Anovion). (c) Natural graphite is geologically common; China's dominance reflects processing investment, not unique geology.
The measure would tilt to severity 5 if China restricts synthetic graphite licences for US or EU anode makers directly, or extends to include battery-grade graphite powder destined for approved FTA partners.
Graphite is the single largest component by mass in a lithium-ion cell (anode) and one of the few critical minerals where non-Chinese supply chains are further behind than in REEs or lithium. The battery supply chain is the primary exposure:
source significant anode precursor from Chinese suppliers.
a structural conflict: US EV buyers need graphite from non-FEOC sources, but >90% of processed anode material is FEOC-eligible under current rules.
spherical graphite producers (Syrah Resources AUS, Nouveau Monde Graphite CA, Westwater Resources US).
This is the third step in the MOFCOM proportional-response playbook, following: 1. July 2023 Ga/Ge licensing (global, severity 4). 2. October 2023 graphite licensing (this filing, global, severity 4). 3. December 2024 Ga/Ge/Sb full ban on US (severity 5, separate filing). 4. April 2025 heavy/medium REE licensing (severity 5, separate filing).
The graphite move was flagged explicitly in the body of the 2023-07-03-china-mofcom-gallium-germanium-export-controls filing as a "subsequent expansion" foreshadowed by the July template.