ROHS Compliance

On November 7, 2025, China’s Ministry of Commerce (MOFCOM) and the General Administration of Customs (GAC) jointly issued Announcement No. 70 of 2025, temporarily suspending several prior export control announcements—Nos. 55, 56, 57, 58, 61, and 62 of 2025—effective immediately through November 10, 2026.

These six announcements, all issued on October 9, 2025, were formulated under the Export Control Law, Foreign Trade Law, Customs Law, and Regulation on the Export Control of Dual-use Items, and introduced export restrictions to safeguard national security and fulfill international non-proliferation commitments.

Key Suspended Announcements

· No. 55 (Superhard Materials): Covered synthetic diamond micropowder, monocrystals, wire saws, grinding wheels, and related DCPCVD equipment and process technology.

· No. 56 (Rare Earth Equipment and Materials): Covered rare earth production equipment, raw materials, and auxiliary substances such as kilns, extraction tanks, and specific flotation and extraction agents.

· No. 57 (Medium and Heavy Rare Earths): Covered metals, alloys, oxides, and compounds of holmium, erbium, thulium, europium, and ytterbium.

· No. 58 (Lithium Batteries and Graphite Anode Materials): Controlled exports of lithium battery materials, graphite anodes, manufacturing equipment, and related technologies.

· No. 61 (Rare Earth Items of Foreign Origin): Extended export controls to foreign-made products containing Chinese rare earths or based on Chinese rare earth technologies.

· No. 62 (Rare Earth-Related Technologies): Restricted export of technologies related to rare earth mining, smelting, separation, and recycling, as well as relevant production line operations and maintenance.

Export Compliance Obligations (Before Suspension)

Exporters were required to obtain licenses from MOFCOM, indicate “Subject to Dual-Use Items” or “Not Subject to Control” on customs declarations, and specify control codes or product parameters as applicable.

Current Status and Next Steps

With the issuance of Announcement No. 70, all the above export control measures are temporarily suspended. From November 7, 2025, to November 10, 2026, exports of these items and technologies will not be subject to the restrictions previously imposed.

MOFCOM and GAC did not provide reasons for the suspension. Affected enterprises are advised to closely monitor further announcements and policy guidance from the authorities to ensure continued compliance once the suspension period ends.