MOFCOM No. 62 Affects La, Ce, NdPr; American RE Roulette; Insect Stops Norway Rare Earth Project; And the lot: Lynas, Energy Fuels, Phoenix Tailings, Rainbow, etc.
Rare Earth 12 November 2025 #187
Note
Another long one. Rare earths are complicated. Another futile attempt to bring some order into the chaos.
Looking into the legalese in MOFCOM Announcement No. 62, it actually affects the remaining four, supposedly unrestricted rare earths - and everything else under the sun suitable for rare earth production. Read on further down.
Is the US rare earth policy perhaps inspired by roulette tables in Atlantic City?
In our Companies section today:
If you think that about twice the natural abundance of rare earths justifies the term “ rare earth deposit” or “project”, then we would recommend picking up a shovel and going mining at a random spot in your neighbourhood. Chance is, that you find higher rare earth contents than Tactical’s Peak “project”.
Ramaco’s coal dust embargo technology is looking for hundreds of millions of dollars.
A beetle stops the most prospective rare earth project of the EU.
Lynas and heavy rare earths? We pulled the data from our mountain of information accumulated over the years, and did the math.
We point at an unnoticed, severe obstacle in the supply chain of MREC from ion-adsorption clays.
There is still residual sanity in rare earths: Phoenix Tailings and Rainbow Rare Earths.
And much more
The rare earth synod in KL
The 21st International Rare Earth Conference in Kuala Lumpur was a roaring success. 215 delegates. Unprecedented candidness everywhere and only a residual few who have not heard the explosions yet that NdPr and dysprosium oxides alone are no solution to any rare earth problem.
USGS lists all rare earths as critical because all of them are critical:
Magnet supply chains
Overall magnet supply chains presented at the conference still depend on China, whether directly or indirectly.
Recent rare-earth metal related arrests and the sentencing of one “traitor” in China should serve notice that reliance on China when making western magnets is a tightrope walk.
Rare earth metal-making is still a gap, in India attended to by Trafalgar in Gujarat State and LCM, UK, with plans for France and USA.
Spreading fear
At least once a month China’s Ministry of State Security launches some rare earth horror story in Chinese media. Chinese rare-earthlings have had their passports confiscated, so they can’t travel outside China. Similar to Communist East Germany’s surveillance state before, being reported by some snitch with sometimes ulterior motives has become a real, advanced, persistent threat for Chinese rare-earthlings. That is personal. Anyone can report on the snitch-site of the Ministry of State Security in Chinese and in English.
Holding a foreign passport and being a naturalised citizen of a foreign country is no protection. If you once had been Chinese, China views you as a Chinese citizen for life.
How did we get here?
Some blame the extraterritorial US technology restrictions on China as the root cause of the rare earth problem. The root actually is older.
The root cause of what is happening today can be found in the Document No. 9/2012 of the Central Committee of the Chinese Communist Party, circulated right after Xi Jin Ping became General Secretary. It is a Declaration of Cold War on the West and on everything the West stands for. The West is viewed as an existential threat to the CCP and Socialism. Why? Because 30 years of “Change through Trade” (political liberalisation through economic interdependence) actually had been enormously successful in China.
Everything we see today in China has its roots in Document No. 9.
The defining feature of Socialism is the continued class-struggle against Capitalism. Often quoted peaceful coexistence is only a transient foreign policy strategy.
You ain’t seen nothing yet
If you think that we have reached the pinnacle of rare-earth acrimony, then you may be mistaken.
The bunker mentality in China is reflected in the Recommendations of the Central Committee of the Communist Party of China for Formulating the 15th Five-Year Plan for National Economic and Social Development.
As regards rare earths:
Transposed on rare earth, self-supporting and risk-resilient certainly refers to cutting import-dependence on rare earth raw materials during the upcoming 5-year plan period.
For 20 years China’’s officialdom has been aware that depending on domestic rare earth resources would be unsustainable at sustained high growth rates and it encouraged “going out” for rare earth raw materials.
But owing to the risk posed by import dependence combined with struggle against the capitalists, the only means of de-risking rare earth raw materials would be cutting imports, increasing domestic mining and overall - in terms of domestic resource sustainability - to produce rare earths for local consumption only.
This is a target that China’s Ministry of Industry & Information Technology already communicated to a raw materials delegation of the EU Commission in 2014.
An increase of the domestic mining quota would confirm the above. But the rare earth quota has become a secret, covered under China’s national security declared on rare earth.
Chinese experts expect a reduction of rare earth separation capacity in China, primarily the private company share.
Reduce trade
As we always point out, Chinese regulation tends to always serve at least two purposes.
To prevent the equalisation of rare earth supply and demand through trade, the recent dual-use license restrictions of 4 April 2025 and the currently implementation-suspended dual-use license restrictions of 9 October 2025 are ideally suited.
China’s imposition of trade war tariffs also on MP Materials’ bastnaesite concentrate in April one may also view as dual purpose. A conscious step in the direction of cutting rare earth import dependence.
Extended reach
Nonetheless, China also is also trying to cripple evolving rare earth production abroad with less than obvious regulation, as you will read further below in this post.
US reaction
The current situation proves that there is no substitute for industrialised nations to having their own rare earth separation from lanthanum to lutetium plus yttrium and rare earth metal production, no matter how small it may be.
The current US government keeps offering large sum of money to anyone who has even only low potential of developing anything in rare earths.
Casino logic
This US approach is reminiscent of playing roulette.
Rather than putting chips on “red” or “black”, “even” or “odd”, with an almost 50% chance of doubling the wager, the US is placing bets on specific numbers with a 35:1 risk of losing the wager.
If there is a hit, however, the pay-out is 35 times the wager plus the wager. And that is what the US think they need in order to prevail in rare earths.
Because time is not on the US side and incremental wins just won’t do the job fast enough. At least this is, what the current US administration may be thinking.
Rare earth hopefuls inflate their capex and acquisition values to get government attention - and receive taxpayer money, for often beyond-hopeless projects. As a famous rare-earthling says:
Junior rare earth miners try to mine both, their deposits and the taxpayers.
At the same time the US government cuts down on renewable energy and EV exposure while pushing its strength, fossil fuels. It makes sense in terms of reducing rare earth permanent magnet demand growth.
It does not replace the need for domestic full rare earth separation, though.
//Politics
The hurray announcement from the White House
The current lull after the great, fearless leaders’ meeting in Korea will not last.
Regardless of the positions taken, the interests of China and the US remain diametrically opposed. At the meeting in Korea, China traded space for time (以空间换取时间) and the relieved US-side went along. This is the reality here.
For the time being the average US tariff on China goods drops to 31%, well below the tariffs the US impose on Brazil, India and some tariffs on Canadian goods. A great success for China.
In its “Fact Sheet: President Donald J. Trump Strikes Deal on Economic and Trade Relations with China” the White House says:
China will suspend the global implementation of the expansive new export controls on rare earths and related measures that it announced on October 9, 2025.
China will issue general licenses valid for exports of rare earths, gallium, germanium, antimony, and graphite for the benefit of U.S. end users and their suppliers around the world. The general license means the de facto removal of controls China imposed in April 2025 and October 2022.
This seemed to contradict the earlier statement from MOFCOM.
The 7 elements under the 4 April 2025 dual-use license restriction had been carefully selected for their particular relevance to the US military-industrial complex. Even under the White House “Fact Sheet” these 7 products remain subject to dual-use licensing. Also refer to MOFCOM announcement of 7 November 2025 below.
Why a “general license” does NOT AT ALL mean the “de facto removal of controls China imposed in April 2025 and October 2022” you can read-up in minute detail in this Substack post.
It is not that the US-officials wouldn’t know. They are just going for an after-sale discount, while boasting the relationship to China has never been better, in order to incentivise China to go along with the after-sale discount.
Bloomberg skillfully put it this way:
The US statement also effectively confirms that China’s export controls on rare earths — which proved a powerful trade weapon for Beijing — remain in place. The “general licenses” mentioned by the White House are a provision under export controls that allow repeated shipments to pre-approved buyers.
Japan’s Aashi Shimbun wrote:
The concessions that President Trump was able to extract were extremely limited, namely a one-year postponement of the tightening of rare earth export restrictions. In return, the US was forced to make a substantial concession by reducing part of the tariffs (10%) that had already been imposed.
Rare earth regulations postponed, a one-year “time bomb”
More importantly, the deadline for the postponement of the tightening of rare earth regulations is only one year.
This “time bomb” clearly demonstrates that the fundamental trade imbalance between the United States and China, as well as structural conflicts over intellectual property rights and technological dominance, remain unresolved. The possibility of restrictions being reinstated in a year’s time remains, putting sustained pressure on the United States and its allies to accelerate the diversification of rare earth supply chains.
China’s indefensible position
China argues that its rare earth dual-use license restrictions are necessary in order to live up to obligations under undefined international non-proliferation of weapons of war agreements.
How effective China’s export licensing is in view of international non-proliferation of weapons one can see in the bloodbath in Sudan, where well-proliferated Chinese weaponry - certainly exported with the proper licenses - plays a major role.
It becomes thoroughly horrific and disgusting if one looks at evidence from recent satellite photos. Piles of what are very likely human corpses and pools of what very likely is blood, visible even from space:
What is being violated here is a human right that even Communists do not dare to dispute, the Article 3 of the Universal Declaration of Human Rights:
Everyone has the right to life, liberty and security of person.
We note that Chinese diplomat Zhang Pengchun 张彭春 served as Vice-Chairman of the original UN Commission on Human Rights, next to Eleanor Roosevelt. China officially celebrates Zhang Pengchun as a committed defender of human rights.
NATO-partner Turkey plus other nations play a role in this dehumanised, barbaric butchery as well. But no other nation involved comes across as a such a self-righteous do-gooder as China’s current government does. This hypocrisy puts China in a politically untenable position.
Suggesting do-good intention, obviously even for actual weapons of war China’s licensing system does not work.
Perhaps China’s dual-use license system is not even supposed to function. In “Eyes only” defense expert Wes O’Donnell explains:
Beijing doesn’t need to send weapons directly to support Russia; it only needs to grease the industrial machinery that keeps Russia’s war running. And it’s been doing that on a near-industrial scale.
Customs manifests show a steady stream of components leaving Chinese ports under deliberately vague descriptions.
A batch of “industrial cooling units” turns up as turbojet engines for glide bombs. “Agricultural drones” are re-routed through shell companies in the Caucasus before appearing in Russian training videos over the Donbas. Semiconductors tagged for consumer electronics find new life in Kalibr missile [Russia’s version of the US Tomahawk] guidance packages.
Denial of access
China needs to worry about its dependence on massive imports of rare earth raw materials from abroad.
One example: Myanmar
In October 2024 the Kachin Independence Organisation (KIO) took control over the rare earth mining operations in Kachin State, the major supply source of rare earths for China. 50% of China’s rare earth import value originates in Myanmar.
Responding to people’s protests about the massive environmental impact Chinese rare earth mining has, the KIO not only closed the one or the other rare earth mine, it also announced the overall discontinuation of rare earth mining within its jurisdiction by end of this year.
It is also a matter of legitimacy. The KIO must prove to the Kachin people better governance than the Tadamadaw or the Tadmadaw’s allies.
China can see the impact clearly, as per this recent article on Xueqiu (“Snowball”):
Myanmar, another major rare earth resource country, relies primarily on its existing stockpiles for external supply due to its own circumstances. However, with these stocks depleted and the rainy season approaching, Myanmar’s ore exports are expected to decrease.
Concretely, Chinese experts warn of a 40% reduction of Myanmar’s rare earth exports to China in 2026. Chinese experts assess Myanmar’s share as 20% of China’s NdPr supply, 50% of China’s dysprosium supply and 70% of China’s terbium supply.
On the other hand, the KIO needs the income from rare earth mining to sustain itself. What if the US chip-in, on the condition that the rare earth mines remain closed?
Enter the frantic expansion of rare earth mining in Myanmar’s Shan State, remote-controlled by China Rare Earth Group.
Self-defeat
China’s dual-use license regulations on rare earths and related course of action actually helps enable the West in rare earths.
The US have hope. As the late David Henderson, a true rare earth gentleman, once said about rare earth:
You can rely on the US to do the right thing, after everything else has been tried and has failed.
China’s October 9 dual-use regulation (suspended for one year) actually covers NdPr oxide - and much more
For the export of non-controlled goods, technologies, or services, if the exporter is aware that the goods or services are used for or substantially contribute to overseas rare earth mining, smelting and separation, metal smelting, magnetic material manufacturing, or rare earth secondary resource recycling activities, an export license for dual-use items must be applied for from the Ministry of Commerce before export, in accordance with Article 12 of the Export Control Law of the People’s Republic of China and Article 14 of the Regulations on Export Control of Dual-Use Items of the People’s Republic of China. Such items may not be provided without a license.
The implementation of the rule is suspended for one year, subsequent to China-US trade negotiation results.
We were mistaken in our assessment that the regulation would not apply to lanthanum, cerium, neodymium, praseodymium and NdPr.
The regulation under Announcement No. 62 reportedly was applied after the announcement date, although its implementation at the time of announcement had been deferred for a month.
This explains the recent strange behaviour of Chinese exporters when they received harmless enquiries for deemed non-controlled rare earth compounds.
Overzealous exporters, or instruction from Beijing?
On review Announcement No. 62 applies to (non-exhaustive list) :
NdPr: For the export of non-controlled goods…if the exporter is aware that the goods…are used for…magnetic material manufacturing…an export license for dual-use items must be applied for from the Ministry of Commerce before export.
NdPr oxide has only one application, metal-making for rare earth permanent magnets.
Consequently, the exporter must be fully aware that the non-controlled export product is for magnetic material manufacturing. This being so, the exporter must apply for a dual-use export license also for NdPr and any other alloy that is likely to be used in rare earth permanent magnet production.
By extension this also applies to separated neodymium oxide, praseodymium oxide and their metals, if the exporter is aware of the application.
Ammonium sulfate/magnesium sulfate/ammonium bicarbonate (or oxalic acid): For the export of non-controlled goods…if the exporter is aware that the goods…are used for…overseas rare earth mining…an export license for dual-use items must be applied for from the Ministry of Commerce before export. Leaching and precipitation of ion-adsorption clays requires these products.
Lanthanum metal: For the export of non-controlled goods…if the exporter is aware that the goods…are used for…metal smelting, magnetic material manufacturing…an export license for dual-use items must be applied for from the Ministry of Commerce before export.
Lanthanum metal may be used for the reduction of samarium oxide to samarium metal - needed for SmCo magnet production.
Cerium oxide/metal: Up to 40% of NdPr in rare earth permanent magnets can be replaced by cerium. Apart from that, cerium could be used for the CeFeB magnet, which is also under technology transfer prohibition.
Everything under the sun related to rare earth separation, recycling, smelting, but expressly not necessarily China-dominated:
Sulfuric acid,
Hydrochloric acid,
Nitric acid,
Di-(2-ethylhexyl) phosphoric acid (D2EHPA),
2-ethylhexylphosphonic acid mono-2-ethylhexyl ester (PC88-A),
Bis(2,4,4-trimethylpentyl) phosphinic acid (Cyanex 272),
Tri-n-butyl phosphate (TBP),
Trialkyl phosphine oxides (Cyanex 923),
Neodecanoic acid,
Kerosene
Sodium oxide,
Sodium sulfate,
Calcium oxide,
Calcium fluoride,
Silica,
Sodium carbonate, and so on and so on
One must stand in awe before the Chinese bureaucracy and its creativeness to regulate everyone & sundry into non-compliance.
If there is no further tension between the US and China, this regulation will remain suspended until 10 November 2026. See below.
The Ministry of Commerce and the General Administration of Customs issued Announcement No. 70 of 2025, announcing the suspension of the implementation of Announcements No. 55, 56, 57, and 58 of 2025 and Announcements No. 61 and 62 of 2025 issued by the Ministry of Commerce and the General Administration of Customs.
[Issuing Authority] Bureau of Safety and Control
[Document Number] Announcement No. 70 of 2025 issued by the Ministry of Commerce
[Date of Issuance] November 7, 2025
With approval, from now until November 10, 2026, the implementation of Announcements No. 55, 56, 57 and 58 of 2025 issued by the Ministry of Commerce and the General Administration of Customs, and Announcements No. 61 and 62 of 2025 issued by the Ministry of Commerce will be suspended.Ministry of Commerce and General Administration of Customs
November 7, 2025
The relevant regulations we covered in our post of 9 October 2025. This also means that the 4 April 2025 dual-use license restrictions remain in force, concerning the 7 rare earth elements most relevant to US defense.
The Ministry of Commerce Announcement No. 72 of 2025 announced the decision to adjust the implementation of Announcement No. 46 of 2024 of the Ministry of Commerce.
[Issuing Authority] Bureau of Safety and Control
[Document Number] Announcement No. 72 of 2025 issued by the Ministry of Commerce
[Date of Issuance] November 9, 2025With approval, from now until November 27, 2026, the second paragraph of Announcement No. 46 of 2024 issued by the Ministry of Commerce (Announcement on Strengthening Export Controls on Related Dual-Use Items to the United States) will be suspended.
Ministry of Commerce
November 9, 2025
The Announcement No. 46 of 2024 we carried in our issue of 7 December 2024.
The second paragraph of Announcement No. 46 reads:
2. In principle, the export of dual-use items related to gallium, germanium, antimony, and super-hard materials to the United States will not be permitted; for the export of dual-use items of graphite to the United States, a stricter end-user and end-use review will be implemented.
It means, that the first paragraph of Announcement No. 46 remains in force:
1. Dual-use items are prohibited from being exported to military users or for military purposes in the United States.
We completely fail in understanding why this is celebrated as a great win when it isn’t, with headlines like China suspends export ban on some rare earth metals to U.S.
A draconian dual-use license regime remains in place. Consequently, same as in rare earths, alternative supplies are the order of the day, because no-one can wait for some bureaucrats in Beijing making up their minds if or not to license the export of every single shipment.
China’s administration has also lived up to other commitments:
Export control on fentanyl precursors (MOFCOM). Includes some very, very common chemical commodities for destination Myanmar, Laos and Afghanistan.
Suspension of Special Port Fees for Ships from the US (Ministry of Transport) until November 2026.
Suspension of Investigations into the Impact on the Security and Development Interests of the Shipping, Shipbuilding Supply Chains (Ministry of Transport) until November 2026.
India may become ‘third pillar’ in US-Japan rare earth network: Analysis - Here’s what ‘buys the breathing space’
“With strong political will and a growing technological ecosystem, India could soon emerge as the third pillar - alongside the United States and Japan - of a democratic rare-earth network,” The Diplomat analysis noted.
India’s rich reserves of rare-earth minerals such as monazite and bastnaesite, found in its beach sand deposits, give it strong raw material potential.
However, the country’s refining and processing capacity has historically lagged due to environmental and regulatory hurdles, something that is now changing, according to Jianli Yang, author of the Diplomat analysis and a research fellow at Harvard University’s Kennedy School of Government.
Earlier in June, India announced plans to negotiate with private firms and introduce fiscal incentives for domestic rare-earth magnet manufacturing to reduce dependence on China.
Companies like Sona Comstar are already setting up magnet production lines, while Indian Rare Earths Ltd. has been directed to expand refining capabilities. The Indian Space Research Organisation (ISRO) is helping adapt high-purity separation technology initially developed for satellites, ANI reported.
India is also linking these domestic efforts to global partnerships under the Quad framework — with the US, Japan, and Australia — to fast-track joint exploration, co-financing, and technology transfer.
Fat hope. All rare earth announcements from India over the years have evaporated. It reminds us of the cynical line: “India is the country of the future. And it will always be.”
If India has no domestic-made rare earth permanent magnets, it will never be an alternative to China. This is it, in a nutshell. Deal with it. Walk the big talk.
Trump hosts Central Asian leaders as US seeks to get around China on rare earth metals
President Donald Trump hosted leaders of five Central Asian countries at the White House on Thursday as he intensifies his hunt for rare earth metals needed for high-tech devices, including smartphones, electric vehicles and fighter jets.
Trump and the officials from Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan and Uzbekistan held bilateral meetings in the Oval Office before having a working dinner.
We do not think this is a good idea. See Kutessay II and Stans Energy, for one typical example. Low RE grades in Kazakhstan and nothing rare-earthy known in Tajikistan or Turkmenistan.
We’ve been through piles of Uzbekistan’s recent geological data. So far nothing regarding rare earths.
Generally nonferrous Tajikistan is firmly in China’s hands. The country is a major part of China’s antimony imports.
//Science
Japan
Watt-level ultrafast 1.75 µm laser system based on thulium-doped core and terbium-doped cladding fluoride fibers
We report watt-level femtosecond pulses in the 1.75 µm region using a thulium-doped core, terbium-doped cladding fluoride (Tm:Tb:ZBLAN) fiber laser system. The seed pulse is generated through stimulated Raman scattering in a silica fiber pumped by an erbium-doped fiber laser. The soliton is subsequently amplified through a multi-stage Tm:Tb:ZBLAN amplifier. The tunability of our chirped fiber Bragg grating stretcher, matched with a Treacy compressor, compresses the pulse to 217 fs. Our system generates ∼250 nJ of single-pulse energy, with a corresponding average power of ∼1 W at a 4 MHz repetition rate. The laser system is suitable for multiphoton microscopy.
Rare earth elements, biomineralization found in plant: study
Chinese researchers have discovered that a fern can accumulate rare earth elements and have observed their “self-assembled” phases inside the plant’s tissues, according to a recent research article published in the journal Environmental Science & Technology.
In this study, researchers from the Guangzhou Institute of Geochemistry of the Chinese Academy of Sciences observed that within the vascular bundles and epidermal tissues of the fern Blechnum orientale, rare earth elements absorbed from the soil precipitate as nanoparticles and further crystallize into a mineral known as monazite-(La).
Monazite is an industrially significant rare earth mineral, primarily formed through geological processes, the researchers said. However, natural monazite often contains associated radioactive elements like uranium and thorium -- posing challenges for its extraction and application.
In contrast, the “biological monazite” formed by the fern Blechnum orientale under natural ambient temperature and pressure conditions is pure, non-radioactive and demonstrates promising potential for the green mining of rare earth elements.
This new study reshapes the understanding of the formation of rare earth minerals, substantiates the feasibility of phytomining, and introduces an innovative, plant-based approach for the sustainable development of rare earth resources.
Right, phytomining. And how much of the planet needs to be planted with ferns to yield a few tons of monazite(La), please?
