Known as "industrial gold", rare earths are strategic resources for new energy, high-end manufacturing and defense. As a key player in the global rare earth industry, China adheres to legal and targeted export controls. On February 24, 2026, China’s Ministry of Commerce issued new export control rules on dual-use items to Japan, including a controlled list and a watch list. We interpret the key points to support compliant Sino-Japanese rare earth trade.
Based on Chinese laws, these rules aim to curb Japan’s rearmament and nuclear ambitions, safeguarding regional security. The measures are legitimate and reasonable. Key requirements for rare earth exports are as follows:
1. Controlled List (20 entities): 20 entities (e.g., Mitsubishi Heavy Industries Marine Machinery & Equipment) involved in boosting Japan’s military capabilities are banned from receiving rare earth exports. Transfer of Chinese rare earths to these entities is prohibited, and ongoing related activities must stop immediately.
2. Watch List (20 entities): 20 entities (e.g., Subaru) with unverifiable end-users/uses are subject to stricter reviews. Exporters can only apply for single-item licenses, submitting risk assessments and commitments that rare earths won’t be used for military purposes. Military-related applications will be rejected. Compliant entities may apply for removal from the list.
3. General Rule: Even non-listed Japanese entities are banned from rare earth imports if linked to military use, forming a comprehensive risk control system.
Notably, these measures target only a few non-compliant entities and dual-use items (e.g., rare earths), not all Japanese enterprises. Normal civil rare earth trade remains unaffected, and law-abiding Japanese entities have no need to worry. China avoids a "one-size-fits-all" approach, balancing security and trade stability.
As a rare earth exporter, we prioritize compliance. We will verify customers against the lists, strengthen end-use checks, and ensure traceability. We will also monitor policy updates to promote stable civil rare earth cooperation between China and Japan, safeguarding the global supply chain.
Feb 27, 2026|
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