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Raw materials and export controls: what ends on 10 November 2026

· Helfen statt Blockieren editorial team

On 10 November 2026, China’s suspension of tighter export controls on rare earths, batteries and superhard materials expires. Almost at the same time, a new version of the EU list of dual-use items enters into force. A situation report for companies working with magnets, electronics or batteries.

What China announced and suspended

On 9 October 2025, China’s Ministry of Commerce and customs administration announced six new controls (Announcements No. 55 to 58, 61 and 62). They covered superhard materials, rare earth equipment and auxiliary materials, five further medium and heavy rare earths, lithium batteries and anode materials, technologies and, with No. 61, also goods from other countries containing rare earths of Chinese origin. With Announcement No. 70 of 7 November 2025, China suspended these rules until 10 November 2026.

The controls of April 2025 remain in force: for seven rare earths, including dysprosium and terbium, and magnet materials made from them, every export needs a licence. According to the EU, China has also been granting general licences to European firms since December 2025. Whether the suspension will be extended, partly ended or fully ended was open at the time of writing.

What the EU is changing itself

On 14 September 2026 the Commission adopted a Delegated Regulation updating Annex I of the Dual-Use Regulation (C(2026)6323). It is due to enter into force in November 2026 and covers, among other things, materials for semiconductor manufacturing and advanced integrated circuits. From then on, affected companies must reclassify their goods; Germany’s export control office BAFA provides a non-binding overview of the changes.

With the RESourceEU plan of December 2025, the EU is making up to 3 billion euros available for 2026, plans joint purchasing and stockpiling through a raw materials platform and a centre for critical raw materials, and restricts exports of certain scrap, such as end-of-life magnets.

What companies should check now

  • Which parts of the bill of materials contain rare earths from China, including via suppliers in third countries?
  • Are alternative sources or stocks in place for the most critical parts for 2027?
  • Has your own list of goods been checked once the new dual-use list enters into force?

According to the DIHK survey “Going International 2026”, 35 percent of companies reporting more trade barriers name export controls as a barrier. This report is not legal advice for individual cases.

Sources

All online sources accessed on 3 November 2026.

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