China bans dual-use exports of gallium, germanium, antimony and superhard materials to the US

Mechanism

Three escalation steps stacked into a single MOFCOM announcement:

1. Dual-use ban — gallium, germanium, antimony, superhard materials. "In principle" no licences will be granted for exports to the US for items with any military end-use; in practice the ban has been near-total since announcement, with shipments slipping toward zero in Dec 2024–Jan 2025 customs data.

2. Graphite end-use review. Stricter case-by-case review for natural and synthetic graphite exports to the US, especially battery-anode-grade material. Not a full ban, but a meaningful chilling effect on the largest single export category by tonnage.

3. Trans-shipment closure. The announcement explicitly addresses re-export to the US via third countries — exporters to non-US jurisdictions face heightened end-user verification if onward shipment to the US is suspected.

The sequencing is the key signal: Dec 2 BIS package, Dec 3 MOFCOM response. This is the most direct tit-for-tat in the post-2022 US-China trade-control cycle.

Why severity 5

China is the dominant supplier for all three named metals:

• Gallium: ~80% of global primary refined output (USGS 2024)
• Germanium: ~60% of global production (USGS 2024)
• Antimony: ~48% of global mine output (USGS 2024)

The ban is on exports to the US specifically, not global exports — but US consumers must now source from third-country producers (Korea, Belgium, Russia, Bolivia for antimony) which in turn source much of their input from China. The DLA strategic stockpile coverage for antimony was already short going in, and prices spiked in the weeks following: antimony futures roughly doubled within 60 days, gallium and germanium spot prices saw ≥30% moves.

Severity 5 because:

• Direct, named target (US) — first time MOFCOM has framed an

export measure this way

• All three metals are at China's structural supply-chain

chokepoints

• Came within 24 hours of a major BIS escalation, signalling a

stable retaliation pattern going forward

Downstream implications

• US Defense Production Act invocations (CHIPS Act materials

funding, DOD strategic-mineral grants) accelerated; Perpetua Resources antimony project, Rio Tinto Kennecott germanium recovery, several gallium recovery projects all gained urgency.

• Western antimony price (Rotterdam metal) spent Q1 2025 well

above pre-ban averages, with downstream effects on ammunition manufacturers (target sector: munitions).

• Wolfspeed, Macom, Coherent (compound-semi makers) telegraphed

multi-quarter inventory draws; some moved to pre-buy non- Chinese stock at premium.

• Cross-references to the Minerals Atlas:

docs/minerals/materials/germanium-gallium.md carries the current price + supply-share table.

Open questions

• This is filed as "export-control" (the action type). It's

arguably "sanction" in spirit. The IPTM taxonomy choice was: if the legal vehicle is export-licensing rather than asset- freeze / OFAC-style designation, file as export-control. Track this in §6 of the charter and revisit if the pattern recurs.

• Quant severity (when scorer ships): gallium share of US-China

bilateral trade is small (<<0.1%), but the strategic-chokepoint qual override pins it at 5 regardless. This is exactly the scenario the qual override exists for.

• Watch the licence-issuance rate over the next 90 days as a

signal of whether the ban is being relaxed for non-military end-uses.