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MOFCOM and GACC publish an updated dual-use catalogue each December for the following calendar year under authority delegated by the Export Control Law of the PRC (2020) and the Regulations on the Export Control of Dual-Use Items (2024). The catalogue is the primary instrument defining what dual-use goods require an import or export licence from MOFCOM. Without a valid licence, a Chinese exporter cannot lawfully ship any listed item; penalties include cargo seizure, revocation of export privileges, and criminal referral under the Export Control Law.
The 2026 catalogue (Announcement No. 91 of 2025) expanded the rare earth section — Item 22 in the catalogue's strategic-materials chapter — with more granular HS-code and compound-level classifications, most notably adding:
defence systems, and high-temperature motors where NdFeB magnets lose coercivity.
GBCAs), in neutron shielding, and as a dopant in phosphors and optical glass.
cancer radiotherapy, e.g., Novartis Lutathera); also used in scintillators and PET scanner crystals.
Each addition requires exporters to obtain a dual-use export licence from MOFCOM's Department of Industry, Commerce and Trade for every shipment. Licence applications are subject to an end-user-statement requirement, post-shipment verification rights, and MOFCOM discretionary approval timelines.
The annual catalogue is architecturally distinct from:
this catalogue is multilateral.
measure; the catalogue is the standing licensing instrument.
suspension of extraterritorial scope does not affect the catalogue's domestic licensing requirements — shipments from China still require a MOFCOM licence for all catalogue items.
mechanism; both apply simultaneously for covered materials.
The catalogue update operationalises China's Export Control Law architecture for the 2026 compliance year and sets the legal baseline for all dual-use licensing decisions.
now subject to MOFCOM discretionary approval. Volume is small relative to NdFeB but irreplaceable for aerospace OEMs (Safran, Honeywell, GE Aerospace).
GE HealthCare, Guerbet) and lutetium-177 radiopharmaceutical producers (Novartis, ITM Isotope Technologies) now face MOFCOM approval timelines on Chinese-origin REE inputs.
broadening pressure on Western REE processors (Lynas, MP Materials, REEtec) to qualify non-Chinese supply chains for these lower-volume but high-criticality compounds.
ensure their Chinese counterparties hold a valid MOFCOM export licence before shipment — failure exposes both the Chinese exporter and the foreign importer to enforcement risk under the Export Control Law's extraterritorial provisions.
lutetium), giving a leading indicator of supply tightness vs. geopolitical selectivity?
on samarium/gadolinium as was done for heavy REEs via Announcement No. 18 of 2025 (April 2025)?
reduce MOFCOM licence-approval risk in their radiopharmaceutical value chains?