China imposes global export licensing on antimony and superhard materials

Mechanism

MOFCOM/GACC Announcement No. 33 of 2024 requires exporters to obtain a dual-use export licence from MOFCOM for all shipments of covered antimony and superhard-materials items, citing the Export Control Law of the People's Republic of China, the Foreign Trade Law, and the Customs Law. Coverage spans 17 HS codes at the 10-digit level across three categories:

Antimony products:

• Antimony ore (blocks, granules, powders, crystals)
• Antimony metal (ingots, blocks, beads, granules, powders)
• Antimony oxides with purity ≥ 99.99% (powder form)
• Organic antimony compounds: trimethyl antimony, triethyl antimony (purity based on inorganic elements > 99.999%)
• Antimony hydride
• Indium antimonide

Smelting technology:

• Gold-antimony smelting technology (classified as a controlled technology transfer)

Superhard materials manufacturing equipment:

• Six-sided top-press equipment (the high-pressure apparatus used to synthesise industrial diamond and cubic boron nitride)

Licences are granted at MOFCOM's discretion with end-user and end-use documentation required. Unlike the December 2024 Announcement No. 46 (which imposed an outright in-principle ban on Ga/Ge/Sb exports to the US), this measure is global in scope: any destination, including the EU, Japan, and Korea, requires a licence for covered antimony items.

Why severity 4

China produces approximately 47% of global mined antimony (USGS 2024 Mineral Commodity Summaries) and an estimated 75-80% of global refined antimony trioxide output. This share is higher than China's germanium or gallium concentration ratios. Antimony's end-use profile is broad and hard to substitute quickly:

• Flame retardants (antimony trioxide): ~60% of global consumption;

used in electronics, textiles, automotive components, aircraft interiors.

• Defence and ballistics: antimony hardens lead for small-arms

ammunition, is used in night-vision infrared optics (indium antimonide), and hardened lead-acid batteries for military vehicles and submarines.

• Batteries: antimony is a grid-electrode additive in lead-acid

batteries (critical for backup-power and telecoms infrastructure).

Following implementation, Chinese export volumes collapsed by approximately 97% on a volume basis in the September–November 2024 period (trade statistics from ITC/ComTrade). Global antimony trioxide spot prices approximately doubled from ~$12,000/t pre-announcement to >$25,000/t by year-end 2024. These are direct, measurable, near-term supply shocks that justify severity 4 on a quant basis.

Bounded below 5 because: (a) non-Chinese primary production (Tajikistan, Russia, Bolivia, Australia, US Stibnite deposit) can expand on a multi-year horizon; (b) antimony is present in legacy tailings at several Western mine sites; (c) the measure permits licences — it is a chokepoint, not a zero toggle for all destinations.

Context in the counter-strike series

This announcement follows the MOFCOM/GACC playbook established with Announcement No. 23 (gallium/germanium, August 2023) and Announcement No. 33 of 2023 (graphite, October 2023). The August 2024 timing — three months after Biden's May 2024 Section 301 tariff hikes that raised duties on Chinese EVs (100%), solar cells (50%), and semiconductors (50%) — places this firmly in the proportional-response architecture.

Announcement No. 33/2024 is the predecessor to the December 2024 Announcement No. 46 (action: 2024-12-03-china-mofcom-ge-ga-sb-export-ban-us), which escalated antimony controls into a US-specific categorical ban one day after the December 2 BIS semiconductor export-control package.

Downstream implications

• US Department of Defense and European defence ministries accelerated

stockpile purchases of antimony trioxide following implementation.

• Perpetua Resources (PPTA) — whose Stibnite Gold Project in Idaho is one

of the few near-term Western primary antimony sources — saw material equity price appreciation and accelerated US government loan negotiations.

• Flame-retardant producers (Lanxess, Clariant, ICL) disclosed antimony

trioxide sourcing disruptions in Q4 2024 earnings commentary.

• The six-sided top-press equipment control creates a barrier for any

greenfield superhard-materials plant outside China, since no major alternative supplier of that press configuration exists.

Open questions

• Licence approval rate monitoring: unlike Ga/Ge, there is limited

public data on how many antimony licences were granted vs. denied in Sept–Dec 2024. A near-zero approval rate effectively mirrors a ban.

• Whether the global scope creates a WTO-inconsistent measure (Article XI

GATT) remains an open question; no formal WTO dispute has been filed.