China MOFCOM Announcement No. 68 (2025) — STE quota regime for tungsten, antimony and silver exports (2026-2027)

Mechanism

Announcement No. 68 operates under MOFCOM's Foreign Trade Law authority over state-owned trading enterprises (STEs) and the Key Export Supervision Catalog (重点出口监管商品目录), not under the Export Control Law / Dual-Use Items Regulations that underpin Announcements Nos. 10/61/62 of 2025. The two regimes are complementary but legally distinct: the dual-use licensing regime polices end-use risk; the STE regime polices who is allowed into the export channel in the first place.

The notice replaces the prior self-reporting STE registration system with a quota-eligibility review + joint approval gate. Provincial commerce departments compile applications and forward them to MOFCOM by 12 November 2025, MOFCOM publishes a 7-day public list of qualified firms, then issues a final review-results notice. The 2026-2027 application cycle covers shipments dated 1 January 2026 onwards.

Eligibility thresholds

Designed to filter out smaller traders and concentrate export privileges among large state-aligned producers:

• All applicants — minimum bank credit line ≥ RMB 200m;

ISO 9000 quality certification; OHSAS 18000 / ISO 45001 health & safety certification; clean social-insurance and regulatory records.

• Tungsten producers (incumbents) — documented exports each

year 2022-2024.

• Tungsten new entrants — three-year average export supply

≥ 2,000 t APT-equivalent.

• Antimony new entrants — ≥ 7,000 t refined antimony or

≥ 5,000 t antimony oxide annual capacity.

• Silver producers — 2024 production proof with 80 t

threshold (less in western regions).

Approved-exporter counts (follow-on review-results notice)

• Silver: 32 incumbent + 12 new approved exporters.
• Tungsten: 14 incumbent + 1 new approved exporter.
• Antimony: 11 incumbent approved exporters.

Why severity 4

• Silver — first-time inclusion in the STE-managed Key Export

Supervision Catalog. China is the world's third-largest silver miner (~14% of global mine output) and a much larger refiner; silver is a critical input to PV cell metallisation paste (~10-15% of demand), AgSnO/AgZnO electrical contacts (defence and grid hardware), and antibacterial / EMI applications. Spot market reaction has been substantial — the 80 t per-firm production threshold concentrates approved-export volume.

• Tungsten — China holds ~80% of global mined output and

~90%+ of refined APT/tungsten-carbide capacity. Compounds the February-2025 dual-use licensing on tungsten metal, alloys and carbide (existing slug 2025-02-04-china-mofcom-tungsten-tellurium-bismuth-molybdenum-indium-export-controls) by adding a second, structurally separate export gate at the STE/quota layer. Almonty Industries Sangdong (Korea) and emerging Vietnam/Australia capacity are the principal ex-China alternatives.

• Antimony — China = ~48% of global mine output and the

dominant refiner. The December-2024 US-only ban (existing slug 2024-12-03-china-mofcom-ge-ga-sb-export-ban-us) cut direct shipments to the US; the STE regime now constrains the indirect re-export channels (Thailand, Mexico, Tajikistan transhipment pathways) by squeezing the universe of Chinese-origin exporters.

Severity 4 (not 5) because the regime remains a gating mechanism on who can export, not an outright country-targeted ban. It nonetheless extends China's structural critical-minerals control architecture into a third legal vector — sitting next to the dual-use export-control regime (Announcements 10 / 18 / 61 of 2025) and the extraterritorial-jurisdiction rules of Announcement No. 61 (existing slug 2025-10-09-china-mofcom-rare-earths-extraterritorial-export-controls).

Downstream implications

• Silver / PV cell paste — Heraeus, DuPont and the Chinese

paste makers (Suzhou Talesun, Wuxi DK) face a re-rated procurement cost curve heading into 2026-2027. PV cell metallisation already accounts for ~140 Moz/year of silver demand; the STE-quota effect raises premia paid for non-Chinese bullion (Pan American Silver PAAS, Hecla HL, First Majestic FSM, Wheaton Precious Metals WPM, SLV/SIL/SILJ ETFs).

• Tungsten primes (Sandvik, Kennametal, IMC/Iscar, Plansee)

and defence base (kinetic penetrators, machine tools) face compounded supply uncertainty. Almonty Industries (5MOZ.AX, ALMR.AX) Sangdong Korea ramp and US-DLA stockpile draws become more strategically important.

• US Antimony Corp (UAMY) — already the named US-domestic

beneficiary of the December-2024 antimony ban; STE quota layer reinforces structural pricing tailwind into 2026.

• Sister actions — pairs with Announcement No. 61 of 9 Oct

2025 (rare-earths extraterritorial controls) and the Feb-2025 dual-use list to form a 2024-2026 strategic-minerals export- control architecture (rare earths, gallium/germanium, graphite, tungsten/antimony/molybdenum/indium/bismuth/tellurium, now silver).

• Trade-truce optics — issued during the Trump-Xi October

rare-earth truce window, signalling that China is preserving proportional-response capacity in non-rare-earth verticals even where rare-earth controls are nominally suspended.

Open questions

• Approval-rate / latency telemetry — does the STE quota in

practice approve >90% of incumbent volume (negotiating instrument) or compress export volume materially (structural choke-point)? First test will be Q1 2026 customs data on silver, tungsten APT and antimony metal/oxide.

• Western-region silver carve-out — the lower 40-80 t

production threshold for western-region producers may be a domestic-development sweetener; track whether it materially shifts the geographic distribution of approved exporters versus prior market share.

• Will the 2027-end review extend to additional minor metals?

— molybdenum, tellurium, bismuth and indium are already on the Feb-2025 dual-use list but not on the STE-quota track. A multi-year reauthorisation in 2027 could fold them in.

• Spillover into LBMA / COMEX silver vault flows — if STE

approval throughput is materially below 2024 export volumes, watch for above-ground inventory drawdowns at LBMA/COMEX into H1 2026 as the differential moves silver pricing.