The People's Republic of China has announced new export controls covering rare earth materials, battery materials, and the technology used to produce them, according to a legal analysis published by the international law firm Mayer Brown.

The measures extend Beijing's export licensing regime into a sector central to global supply chains for electric vehicles, energy storage systems, and consumer electronics. Exporters of the controlled materials and technologies will now need to obtain licences from Chinese authorities before shipping goods or technical know-how out of the country.

China dominates global production of rare earth elements and processed battery inputs. Previous rounds of export controls imposed by Beijing — including the December 2023 restrictions on gallium, germanium, and graphite, and the 2024 expansion covering antimony and other critical minerals — triggered compliance reviews across the semiconductor, defence, and battery manufacturing sectors. The new controls move further down the value chain, targeting not only the materials themselves but also the process technology associated with them.

For multinational manufacturers, the practical consequences are immediate. Companies that source rare earth compounds, battery cathode and anode materials, or related production equipment from Chinese suppliers must assess whether their products now fall under licence requirements. Technology transfer arrangements — including licensing agreements, engineering services, and technical assistance provided to overseas facilities — may fall within the scope of the controls as well.

Mayer Brown's analysis advises firms to take several steps: screen current and pending contracts against the new control lists, identify whether any exports or deemed exports of controlled technology require licences, and review supply agreements for force majeure and compliance clauses that allocate the risk of licence denials.

The controls also raise questions for companies operating joint ventures in China. Export control law in the PRC can apply to technology disclosed to foreign nationals inside China, a category regulators treat as an export. Firms with Chinese R&D operations or manufacturing partnerships should evaluate whether routine technical exchanges now trigger licensing obligations.

Trade lawyers note that Chinese export control enforcement has tightened since the 2020 Export Control Law took effect. Penalties for violations include fines, suspension of export privileges, and potential criminal liability for responsible individuals. Customs authorities have also increased scrutiny of shipments containing dual-use items and critical minerals.

The timing places additional pressure on governments and manufacturers pursuing supply chain diversification. The European Union, the United States, and Japan have each announced funding programmes aimed at reducing dependence on Chinese processing capacity for rare earths and battery materials. Building alternative processing capacity takes years, and few facilities outside China currently operate at commercial scale.

Importers outside China now face a choice: apply for Chinese export licences and accept the associated approval timelines and conditions, or accelerate qualification of non-Chinese suppliers at higher cost. Battery cell manufacturers in South Korea and Japan, which import significant volumes of Chinese precursor materials, are likely to feel the effects first.

Mayer Brown recommends that affected companies maintain documented compliance programmes and engage with Chinese licensing authorities early, since application processing times can extend delivery schedules. Firms should also monitor follow-up implementation notices, as Chinese ministries typically issue clarifying guidance — including licence application procedures and commodity code listings — in the weeks following an initial announcement.

Companies with questions about specific transactions should consult counsel familiar with PRC export control regulations before proceeding with shipments or technology transfers that may now require authorisation.

Die Signal will continue to track implementation details as Chinese authorities publish them.