China Export Controls: Rare Earths & Dual-Use Items Impact Guide for Japanese Procurement
For Japanese companies sourcing magnets, electric motors, electronic components, and specialty alloys from China, the recent trends in Chinese export controls—particularly concerning rare earth elements and dual-use items—have become a critical factor influencing supply chain stability.
However, in day-to-day operations, there is a widespread misunderstanding that needs to be addressed first.
[Common Misconception]
“Because this product contains rare earths, it can no longer be imported into Japan (or exported from China).”
To put it simply, this statement is incorrect.
China’s export control system does not determine eligibility based solely on whether a product contains rare earth elements. Instead, decisions are made based on “which specific items, chemical compositions, and specifications fall under controlled lists” and “whether the end-user and end-use comply with regulatory standards.”
Therefore, procurement managers should not abandon procurement plans simply because of the term “rare earth.” Instead, they must systematically verify and evaluate key compliance criteria prior to placing orders.
1. First Check: Which Category Does Your Product Belong To?
When holding technical discussions or requesting quotes from Chinese suppliers, do not rely on generic product names such as “rare earth product,” “strong magnet,” or “rare earth alloy.” Always request detailed material specifications and chemical composition standards.
Key Checkpoints by Product Category
| Product Category | Main Verification Items & Checkpoints |
|---|---|
| Rare Earth Metals, Oxides, Compounds | Specific constituent elements and verification against export control lists. |
| Magnetic Materials (NdFeB, SmCo, etc.) | Specific material grades, added elements (Dy/Tb, etc.), dimensions, coercivity, and magnetic specs. |
| Components & Parts (Motors, Sensors, etc.) | Specifications of internal magnetic materials and overall finished product attributes. |
| Special Alloys, Equipment, Machinery | Elemental content, technical parameters, and dual-use classification status. |
For example, simply hearing a supplier state that “this is a rare earth magnet” is insufficient. Japanese procurement officers must obtain explicit material names, listed rare earth elements, and detailed technical specifications, while requesting official documents such as SPEC sheets, SDS (Safety Data Sheets), or Mill Test Certificates.
Important Note Regarding HS Codes
An HS Code is merely a customs classification standard and cannot be used as definitive proof that an item is exempt from export controls. Final eligibility must always be determined by cross-referencing exact technical parameters with China’s official Export Control Catalog.
2. “Export Controlled” Does Not Mean “Export Banned”
Even if a product falls under export control regulations, it does not mean exports to Japan are immediately blocked.
Most controlled items are managed through an export licensing system. By following prescribed administrative procedures and obtaining an official Export License, shipments can proceed normally. Whether a license is required—and whether it will be approved—depends on specific product parameters and transaction details.
Therefore, instead of asking Chinese suppliers a vague question:
“Can this item be exported to Japan?”
You should provide a precise inquiry:
“Does this product fall under China’s current export control lists (including dual-use items)? If so, what type of export license is required for shipments to Japan?”
Key Updates: Ministry of Commerce Announcement No. 1 (2026)
On January 6, 2026, China’s Ministry of Commerce issued Announcement No. 1 of 2026, strengthening export controls on dual-use items destined for Japan. This measure explicitly prohibits the export of dual-use items to Japanese military end-users, military applications, or any end-use that contributes to boosting Japanese military capabilities.
Consequently, for products that may be classified as dual-use items, verifying the end-user and end-use is just as critical as checking product specifications.
For standard civilian applications—such as consumer electronics, apparel, automotive parts, and industrial machinery—procurement can proceed lawfully by submitting accurate End-User Certificates and completing required license applications.
3. Five Key Questions to Ask Chinese Suppliers Before Ordering
To avoid customs delays or failed shipments after mass production is complete, buyers should ask suppliers these five questions during the quoting and sampling stage:
- What are the exact material specifications and chemical compositions? Does it contain regulated rare earth elements?
- Can you provide technical specification sheets (SPEC), SDS, or Mill Test Certificates?
- Does this product fall under China’s current export control catalog or dual-use item lists?
- If an export license is required, does your company (or export agent) have prior experience applying for it? What is the estimated lead time?
- Have you successfully exported identical or similar products to Japan under current regulations?
4. Ideal Procurement Workflow for Magnets, Motors, and Alloys
To prevent supply chain disruptions, follow this recommended standard operating procedure:
- [ Step 1 ] Confirm material grades and technical parameters.
- [ Step 2 ] Verify eligibility against Chinese export control lists.
- [ Step 3 ] Confirm end-user/end-use status and determine export license requirements.
- [ Step 4 ] Issue purchase orders and commence manufacturing (mitigating post-production risks).
Thorough pre-order verification is the cornerstone of effective risk management in international procurement.
Summary
When evaluating Chinese export restrictions on high-performance materials, Japanese companies must focus on two core questions rather than simply asking if rare earths are present:
- Is the product specifically listed on a controlled items catalog?
- Do the transaction’s end-user and end-use comply with regulatory restrictions?
Export control policies evolve rapidly. Working closely with trading partners and local suppliers ensures compliance while maintaining a stable, resilient supply chain.
Reference (Official Information):
China Ministry of Commerce Announcement No. 1 of 2026: “Announcement on Strengthening Export Controls on Dual-Use Items to Japan”
Note: This article is intended solely for general business reference and does not constitute legal advice. For specific transactions, consult official regulatory authorities in China and Japan.