On June 24, the Ministry of Commerce officially issued Announcement No. 26 of 2026. New regulations on export control reporting of strategic mineral dual-use items will be officially implemented on July 1.
In the past, most market participants only regarded it as a regular administrative regulatory document, noting that the policy covered core strategic resources such as rare earths, gallium germanium, tungsten, medium and heavy rare earths, and helium. However, the core breakthrough of this policy is to make up for the regulatory shortcomings of previous years: it is clearly listed
13 types of illegal situations will be included in the scope of strict investigation, including detouring through third countries for transshipment, splitting raw materials into parts and components, illegal transfer of smelting technology, and freight forwarders assisting in smuggling. At the same time, an online reporting channel for all people will be opened to achieve closed-loop supervision of the entire chain.
For a long time, domestic strategic minor metals have always been in trouble: upstream mines strictly implement total mining volume control, and production capacity shrinks year by year, but spot prices have been difficult to reasonably reflect for a long time.
The core problem is not excess domestic supply, but various gray export channels that continue to divert supply, directly hedging the supply and demand dividends brought about by production restrictions.
Formal exports are strictly restricted by quotas, but transit smuggling is unimpeded. Scarce resources continue to flow out, and the strategic value of resources has never been fully realized.
Based on customs investigation cases and the actual situation of the foreign trade industry, overseas buyers have already formed a mature set of evasion control routines, and four secret channels have long-term diversion of strategic mineral supply: The first is re-export to a third country to launder the origin. Domestic minerals are first exported to transit countries with loose export policies such as Thailand, Mexico, and Malaysia, and the packaging is changed and tampered with in the bonded area.
The certificate of origin is changed, transformed into “overseas self-produced raw materials” and then transferred to the European and American markets. The most typical example is that after antimony export controls were implemented, the export volume of antimony from Mexico and Thailand surged dozens of times in a short period of time. However, these two countries have almost no local smelting capacity, and the source of the goods is clear at a glance; the second is to break the whole into parts, split the raw materials into parts, and convert high-quality antimony into parts.
Pure tungsten powder, germanium ingots, and rare earth metals are processed into small hardware accessories and mechanical semi-finished products. Customs commodity codes are changed to avoid dual-use item inspections. Controlled mineral raw materials are disguised as ordinary industrial products and shipped in batches. It is difficult for supervision to verify each piece. The third is to export false product names, and mix controlled metal powder into ordinary ores, chemical coatings, and metal castings.
At the bottom level, low declared value, concealed name of goods, relying on blind spots for inspection of large-volume shipments in containers lead to bulk outflow; fourth, along with the simultaneous outflow of process technology, through joint research and development, overseas factory construction, technical consultation, etc., the purification and smelting technology of gallium, germanium, and rare earths are exported to the outside world, and factories are built overseas to digest domestic primary raw materials, bypassing the export licensing system.
The reporting mechanism, which was launched in July, has completely filled the regulatory loopholes and directly upgraded the supervision intensity: first, the scope of law enforcement covers the entire industrial chain, not only punishing export companies, but also all freight forwarders, freight companies, customs brokers, e-commerce platforms, and financial institutions that assist in illegal transshipment and splitting of goods will be punished.
Being held accountable, the entire smuggling profit chain was cut off, and 13 types of violations were written in black and white. Detoured exports, parts disassembly, and technology transfer were all clearly included in the hit list, leaving no room for vague law enforcement. Secondly, the supervision model changed from departmental special inspection to nationwide social supervision, and the Ministry of Commerce launched a dedicated online reporting
Platform, a dedicated reporting hotline is simultaneously opened, and any individual can submit clues. Real-name reports will also receive feedback on case-by-case handling, forming a long-term deterrent. Small and medium-sized traders will no longer dare to take risks, and the short-term gray export supply will shrink off a cliff; finally, the scope of control will be extended to high-purity industrial gases.
Helium has also been included in this resource control list. Previously, many traders split and filled controlled high-purity helium and exported it overseas through transit trade. As export review tightens, self-produced helium will give priority to meet the rigid needs of domestic medical nuclear magnetic field, memory chips, and aerospace fields, and domestic spot circulation will further tighten.
Upstream mining locks up production capacity, and downstream blocks the hidden channels for resource outflow. With one block and one block, the domestic supply of strategic minerals that can be circulated will steadily shrink. The supply of goods that originally flowed overseas will remain in the local market, and the tight balance between supply and demand has officially escalated to oversupply.
From the perspective of both supply and demand, there is a double tightening on the supply side: on the one hand, domestic key mineral mining rights continue to tighten, and approvals for new mines are basically suspended; on the other hand, gray export channels are blocked, diversion sources of goods are significantly reduced, and commodity supply continues to shrink.
Demand-side rigidity is stable in the long term: gallium and germanium support military radars and third-generation semiconductors; tungsten and antimony are core raw materials for high-end cutting tools and infrared weapons; medium and heavy rare earths are bound to new energy motors and aviation equipment; high-purity helium serves chip manufacturing and medical equipment. All downstream industries are high-prosperity rigid demand industries, and demand maintains steady growth.
With the gap between supply and demand continuing to widen, the market differentiation of related categories is clear: the first echelon is medium and heavy rare earths, tungsten, and antimony. These resources have the largest scale of transit smuggling in the past. After the New Deal seals the loopholes, the supply contraction effect is the most direct and the spot price elasticity is the strongest; the second echelon is gallium,
For germanium, indium and bismuth, my country occupies the vast majority of the world’s production capacity. Export controls have raised overseas procurement costs, and domestic spot premiums have continued to rise. The third echelon is self-produced high-purity helium-related categories. Overseas imported supply continues to be in short supply. If domestic resources are not outflowed, high spot prices will be maintained for a long time.
In the past, relying solely on mining quota control could only control the supply of goods with formal customs declarations, but could not stop all kinds of transit trade. The outflow of resources continued to suppress the room for price increases.
The universal reporting supervision mechanism, which was officially implemented on July 1, has completely sealed the two core loopholes of third-country transit and splitting of parts and components, and export control has finally formed a closed loop.
With upstream production restrictions and downstream outflow channels locked, the supply and demand pattern of strategic minerals such as rare earths, tungsten, gallium germanium, and helium has experienced a substantial reversal under the resonance of dual policies.
In the short term, the clearance of gray supply will push up the tightness of domestic spot inventories; in the medium and long term, the asset value of scarce strategic resources will usher in a round of comprehensive revaluation, and the market will completely shift from theme speculation to fundamentals.
