China has not published a notice extending its suspension of export controls on rare earths and related items, which is written to end on November 10. The US Commerce Department extended its own pause on a 50 percent ownership rule through January 10, 2027, in a rule filed on November 5. A check of the Chinese Commerce Ministry’s policy list and export-control website on November 6 found no announcement changing the November 10 date. The list’s newest entries that day covered anti-dumping investigations and shipping insurance.

The ministry’s Announcement No. 70, issued with China’s customs agency on November 7, 2025, suspended six export-control announcements from the previous month until November 10, 2026. According to Pillsbury, they cover five more rare earth elements, rare earth processing equipment and technologies, lithium battery and graphite anode materials, and synthetic diamonds and other superhard materials.

Announcement No. 61, which Pillsbury describes as China’s first attempt at an extraterritorial export-control rule, would require licenses for certain foreign-made items containing Chinese-origin controlled rare earths worth 0.1 percent or more of their value. It says applications would be reviewed case by case when the end use is research or production of logic chips at 14 nanometers and below, memory chips with 256 or more layers, the equipment and materials used to make them, or AI with potential military uses.

The ministry said on September 28 that the two sides had agreed to extend their Kuala Lumpur arrangement, under which “certain tariff and non-tariff measures” were suspended until November 10, to January 10, 2027, and to keep discussing a solution. The statement does not mention rare earths or Announcement No. 70. The ministry said it believes the two sides will work toward a solution for “further extension” before the end of the year. Crowell & Moring has described the original deal as the US suspending the Affiliates Rule in exchange for Beijing suspending its rare earth restrictions.

The ministry could still act at short notice. Last year it published Announcement No. 70 on November 7, three days before the US suspension took effect, and a related notice on November 9.

That related notice, Announcement No. 72, runs on a different schedule. It suspends until November 27 restrictions on exports to the United States of dual-use items related to gallium, germanium, antimony and superhard materials. Pillsbury’s November 2025 alert lists the ban on dual-use exports to US military users and the April 2025 licensing of seven rare earth elements as still in force. It told clients that “the legal framework remains intact” and that they should keep mapping Chinese-origin content in their supply chains.

The ministry has kept issuing other export-control measures. Its list shows notices dated October 19 on shield tunneling machines, dredgers and drones, and the October 16 proposal to restrict AI technology exports.

Sources: China’s Ministry of Commerce (Announcement No. 70), China’s Ministry of Commerce (September statement), Pillsbury

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By the Control Plane Editorial Team