China MOFCOM tungsten/tellurium/bismuth/molybdenum/indium export-licensing controls

Mechanism

Issued under the Export Control Law of the PRC (2020), the Foreign Trade Law, the Customs Law, and the Regulations on the Export Control of Dual-Use Items (Dec-2024 framework that consolidated MOFCOM's licensing authority for civilian-but- sensitive materials). Items in scope include:

• Tungsten — metal and alloys with W content ≥ 97% by weight

(excluding items already controlled under 1C226 / 1C241), plus W-Cu composites with W content ≥ 80%; W-Re alloys; tungsten carbide; ammonium paratungstate (APT) intermediate.

• Tellurium — high-purity Te, CdTe, CdZnTe and HgCdTe single-

and poly-crystal substrates (the primary cadmium-telluride solar PV input + infrared-imaging substrate).

• Bismuth — metal Bi and bismuth-based products (ingot, lump,

bead, granule, powder), Bi-Te alloys, bismuth oxide.

• Molybdenum — Mo powders specifically usable in missile

components (Mo content ≥ 97%, particle size ≤ 50 μm), plus Mo alloy granules and Mo-Re alloys.

• Indium — high-purity In, In-Sn oxide (ITO) targets, indium

phosphide (InP), indium arsenide (InAs), and related compound- semiconductor substrates.

Exporters must obtain a dual-use item export licence from MOFCOM before shipping any listed item to any destination. The controls are not country-targeted on their face; the contemporaneous US-only measures (2024-12-03 Ga/Ge/Sb ban; 2025-04-04 heavy-REE licensing) suggest licence approvals to US destinations will be selectively delayed or denied even though the rule is nominally global.

Why severity 4

• Tungsten: China holds ~80% of global mined output and ~90%+

of refined APT/tungsten-carbide capacity. Used in defence (kinetic penetrators, armour-piercing rounds), machine tools, and oil/gas drilling — direct line to US/EU industrial supply chains.

• Tellurium: China = ~60% of refined Te. CdTe is the substrate

for First Solar (FSLR) thin-film modules — the only non-Chinese utility-scale PV technology — and for the only commercial long-wave IR detector substrate (HgCdTe).

• Bismuth: China = ~80% of global mined Bi and >90% of refining.

Bi displaced lead in solders and pharmaceuticals; bismuth telluride is the dominant thermoelectric material.

• Molybdenum (powder ≥ 97%, ≤ 50 μm): Narrow but defence-

critical sub-category — these specs match missile-component usage and electron-tube anodes. Most commercial Mo trade is unaffected; the targeted spec is significant for primes.

• Indium: China = ~60% of refined In. ITO is the transparent

conductor in essentially all flat-panel displays and touch screens; InP is the substrate for high-speed photonics and 5G RF semiconductors.

This is the fifth in MOFCOM's structural critical-minerals control sequence (Ga/Ge → graphite → Ga/Ge/Sb US-ban → heavy REE → W/Te/Bi/Mo/In). It widens the playbook from a handful of chip/defence-relevant materials to broad industrial inputs — solders, drilling, machine tools, displays, solar — affecting many more downstream sectors than prior tranches. Severity 4 rather than 5 because the rule remains a licensing regime (not an outright country ban) and several listed items have non-trivial ex-China supply (Mo: US/Chile/Peru; Bi: by-product of Pb refining; W: Vietnam, Russia, Bolivia, Australia re-emerging).

Downstream implications

• First Solar (FSLR) — Te is the binding constraint on CdTe

module output. Pre-existing 5N tellurium offtake from 5N Plus (VNP.TO) in Quebec partially insulates near-term, but expansion to >25 GW/yr CdTe capacity becomes harder.

• Tungsten primes (Sandvik, Kennametal, IMC/Iscar) — APT spot

price up >30% in Q1 2025 on the announcement; offtake interest in Almonty Industries (5MOZ.AX, ALMR.AX) Sangdong Korea mine re-rated.

• Defence base — DLA strategic stockpile gaps on W and Te

flagged in DoD's annual Industrial Capabilities report; expect accelerated DPA Title III obligations to MP Materials, Almonty, and US Antimony (UAMY) follow-ons covering W and Te.

• EU CRMA — W and Mo are on the EU Strategic Materials list;

this measure is a stress-test of the 2024 CRMA's domestic-share benchmark (10% extraction, 40% processing, 25% recycling, ≤65% single-third-country).

• Pricing — APT (W) and bismuth metal both rallied

double-digits in the weeks after publication; indium and molybdenum less responsive given larger ex-China supply pools.

Open questions

• Will MOFCOM extend to neodymium / praseodymium (the

highest-volume rare earths, conspicuously absent from the April 2025 heavy-REE list)? This remains the single most- watched escalation in the sequence.

• Licence-approval throughput — published statistics from the

earlier Ga/Ge/graphite tranches will be a leading indicator of whether this measure functions as a structural choke-point (low approval rate, long latency) or a negotiating instrument (high approval rate, short latency).

• Whether China subsequently issues a US-specific ban (cf.

2024-12-03 Sb/Ge/Ga full ban to US) on any subset of these items if Trump-administration tariff escalation continues.

• Status of the Nov-2025 Trump-Xi truce: late-2025 reporting

(Pillsbury, Oct-2025) indicated MOFCOM had suspended parts of the export-control regime through Nov-2026 as part of the trade-truce package — verify the current operational status and consider a follow-up 2025-11-XX-china-mofcom-export- controls-suspension-truce action when the suspension's scope is fully published.