On November 9, 2025, China’s Ministry of Commerce (MOFCOM) issued Announcement No. 72 of 2025, temporarily suspending the enforcement of Article 2 of Announcement No. 46 of 2024—which strengthened export controls on certain dual-use items to the United States. The suspension takes immediate effect and will remain in place until November 27, 2026.
Originally, Announcement No. 46 of 2024, effective December 3, 2024, restricted exports to the U.S. of dual-use items related to gallium, germanium, antimony, and ultra-hard materials, and imposed stricter end-user and end-use reviews on dual-use graphite exports. These measures were implemented under China’s Export Control Law to protect national security and fulfill international non-proliferation commitments.
While the suspension temporarily eases restrictions on these materials, Article 1 of the 2024 announcement—prohibiting exports to U.S. military end-users or for military end-uses—remains fully in force. Companies must continue to comply with these rules, and violations will be subject to legal penalties.
This policy adjustment provides a temporary window for Chinese enterprises exporting to the U.S. to reassess their strategies and manage trade activities involving gallium, germanium, antimony, ultra-hard materials, and graphite. Businesses are advised to monitor further policy updates closely and ensure compliance to mitigate trade and regulatory risks.
