China Imposes Export Control Measures on Graphite Materials

On October 20, 2023, China’s Ministry of Commerce and the General Administration of Customs jointly issued an announcement regarding the temporary export control measures on graphite materials. Some materials will be subject to export control, and three highly sensitive graphite materials including spherical graphite, which were previously subject to temporary control, will be included in the list of dual-use items for export control. Moreover, temporary control measures on five low-sensitivity graphite materials primarily used in industries such as steel, metallurgy, and chemicals, including carbon electrodes of a kind used for furnaces, will be removed.

The control measures take effect on December 1, 2023 .

Substances with the following properties will be banned from export unless there is permission:

Serial No.	Substance	HS code (for reference)
1	Artificial graphite materials and related products with high purity (purity > 99.9%), high strength (flexural strength > 30 MPa), and high density (density > 1.73 g/cm³).	3801100030, 3801909010, 6815190020
2	Natural flake graphite and its products, including spheroidized graphite and expanded graphite.	2504101000, 2504109100, 3801901000, 3801909010, 3824999940, 6815190020

Operators dealing with these materials are required to obtain the necessary export approval documents. They should submit applications to the competent authorities and complete the Application for Dual-use Items and Technologies. Additionally, the following documents must be submitted:

1. Original sales contract or agreement or its duplicates or scanned copy;
2. Technical specifications or test reports for materials intended to export;
3. Supporting documents related to end user or end-use;
4. Introduction of importers and end users; and
5. Identification of legal representatives, major operators, and agents.

The Ministry of Commerce, either independently or in collaboration with relevant departments, will conduct a review from the date of receiving applications and issue permissions within specified time limits. For the export of items listed in this announcement that have a substantial impact on national security, the Ministry of Commerce, in conjunction with relevant departments, will submit a report to the State Council for approval. If approved after the review, the Ministry of Commerce will issue licenses for dual-use items and technology export permits.

According to the Ministry of Commerce, it is international practice to implement export control measures for specific graphite materials. As the world’s largest producer and exporter of graphite, China remains committed to fulfilling its international obligations related to non-proliferation and to imposing export control measures on specific graphite materials and temporary control measures on some graphite materials based on the need to safeguard national security and interests. In accordance with the Export Control Law of the People’s Republic of China, the Chinese government conducted a comprehensive assessment of temporary control measures on graphite materials and made optimized adjustments. This decision reflects a commitment to fulfilling international obligations related to non-proliferation, ensuring the security and stability of the global graphite supply chain, and safeguarding national security and interests. China’s adjustment of export controls is a routine measure and is not targeted at any specific country or region. Exports that comply with relevant regulations will be permitted.

CIRS comments

Control measures on highly sensitive graphite materials are estimated to directly impact the global supply chain, particularly in sectors related to alternative energies, where these materials are frequently used.

In July of this year, China announced export control measures on substances, including gallium and germanium, used in the semiconductor sector. These control measures will inevitably have a significant impact on global supply chains in industries such as new energy and semiconductors, especially when considering the current control measures on graphite.

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Further Information

Official notice in Chinese