Latest Developments in China’s Export Licensing Regime for Critical Minerals

Key Takeaways

• General export licenses are expanding but tightly managed, with one-year validity and quarterly volume caps that constrain operational flexibility.
• Distributors, trading companies, and new customers with unclear transaction backgrounds and opaque resale structures face heightened scrutiny, even for nominally civilian products.
• Japan-related cases face a higher risk of delay in the face of new controls.