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China Imposes Export Control on Graphite and Related Products

Exporters of regulated graphite and related products must apply for export license prior to custom clearance.

On October 20, 2023, China's Ministry of Commerce and the General Administration of Customs jointly published Announcement No.39 of 2023 to implement export controls on certain graphite and its products.  It shall take effect from December 1, 2023. 

Specifically, graphite and its products that meet the following characteristics will be officially managed as dual-use items: 

Items
HS code (for reference)
High-purity (purity>99.9%), high-strength (flexural strength>30Mpa), high-density (density>1.73g/cm3) artificial graphite materials and their products3801100030、3801909010、6815190020
Natural flake graphite and its products (including spheroidized graphite, expanded graphite, etc.)2504101000、2504109100、3801901000、3801909010、3824999940、6815190020

To export these items, it is required to apply in advance to Ministry of Commerce and obtain an export license for custom clearance.

In the meantime, temporary export controls on graphite-related items listed under Decision to Implement Temporary Export Control on Graphite Related Products (Announcement No. 50 of 2006 by the Ministry of Commerce, the State Commission of Science, Technology and Industry for National Defense, and the General Administration of Customs) are abolished.

It is important to note that expanded graphite (HS code: 3824999940) and surface-treated spheroidal graphite (HS code: 3801901000) are designated as temporary controlled items under the Catalogue of Dual-Use Items and Technologies Subject to Import and Export License Administration (2023) published in December of 2022. In the future, the Catalogue will update to include these items along with other designated items under official export control. 

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