China MOFCOM + MOST Announcement No. 28 (2025) — Revision of Catalogue of Technologies Prohibited/Restricted from Export (Battery Cathode, Lithium, Gallium Processing)

Mechanism

The Catalogue of Technologies Prohibited or Restricted from Export is a joint MOFCOM/MOST instrument (distinct from the dual-use goods Export Control Law regime) that gates the transfer of Chinese-origin process technology and know-how — not just physical goods — via a licensing requirement administered case-by-case. The July 2025 revision (Announcement No. 28) is the first amendment since the full-catalogue republication in December 2023 (Announcement No. 57) and follows a public-consultation draft circulated in January 2025 that proposed adding one entry, modifying one, and deleting three.

The substantive addition targets upstream battery-material process technology rather than the minerals themselves: preparation technology for LFP (lithium iron phosphate) and LMFP (lithium manganese iron phosphate) cathode materials, lithium carbonate/lithium hydroxide preparation technology, and gallium processing technology. This complements — rather than duplicates — the mineral-and-goods-focused export licensing actions MOFCOM has issued under the separate dual-use export control list (gallium/germanium in 2023, graphite in 2023, antimony in 2024, rare earths through 2025). Where those controls gate the export of the material itself, this catalogue gates export of the process technology to make the material — a harder-to-reverse lever, since it constrains foreign capacity-building rather than a single shipment.

The catalogue does not disclose licence-denial rates or a quantified trade value, so severity is set qualitatively at the level of prior single-material MOFCOM technology/export-control revisions in this series (severity 3) — narrower in material scope than the 2025 rare-earths or antimony/tungsten actions, but notable for the process-technology mechanism.

Downstream implications

• Extends China's control perimeter over battery supply chains from mined/refined material

(lithium, graphite, rare earths) to the process technology used to convert them into cathode materials — a lever aimed at slowing foreign LFP/LMFP capacity build-out (India, Morocco, Indonesia, US) rather than a single trade flow.

• Gallium processing technology control complements the existing gallium metal/compound export

licensing regime (2023-07-03 action) by also gating equipment/know-how transfer.

• No sunset or review date specified in the announcement; treat as a standing addition to the

catalogue pending a future revision.

Open questions

• Whether MOFCOM has issued or will issue implementing guidance quantifying licence-approval

rates or processing times for the new cathode/lithium-salt technology entries.

• Whether this technology-transfer control will be paired with a corresponding goods-export

licensing requirement for LFP/LMFP cathode material itself (as happened with graphite in 2023).