MOFCOM FAQ 2025 #4 definition and examples

Based on recent enterprise inquiries and after communication with relevant

departments of the General Administration of Customs, answers to common

identification questions regarding medium and heavy rare earth-related items

are provided as follows:

1. Are there specific requirements for the rare earth content in relevant alloys and targets?

For controlled items such as alloys and targets listed in the announcements, the control scope includes both alloys and targets containing only the listed

elements, as well as those containing both the listed elements and non-listed

elements. The following products serve as examples:

① A "magnesium alloy" with the specification "Gadolinium 12%, Magnesium 70%, Nickel 6%, Neodymium 4%, Zinc 3%, the rest composed of aluminum, manganese, iron components" falls within the scope of the controlled item

"gadolinium-magnesium alloy".

② "Aluminum alloy powder" with the specification "Aluminum 70%-90%, Magnesium 1%, Scandium 1%" falls within the scope of the controlled item "scandium-aluminum alloy".

③ "Nickel alloy powder" with the specification "Nickel 55%, Samarium 37%,

Lanthanum 4%, Magnesium 0.22%" falls within the scope of the controlled item "samarium-nickel alloy".

④ An "aluminum alloy sputtering target" with the specification "Aluminum 98%, Scandium 2%" and an "aluminum scandium nitride target" with the

specification "Aluminum Nitride 60%, Scandium Nitride 40%" both fall within the scope of the controlled item "scandium target".

2. How is the concept of "mixture" understood?

A "mixture" refers to a simple physical mixture of controlled items, without a

fixed chemical formula, composition, or properties. The various components

have not undergone a chemical reaction and retain their original properties. The following products serve as examples:

MOFCOM FAQ 2025 #4 definition and examples 1

① A "slurry (solution)" with the specification "Pure Water 50%, Barium

Carbonate 30%, Yttrium Oxide 12%, other trace oxides totaling 8%" falls within the scope of the controlled item "mixture of yttrium oxide".

② A "mineral earth desiccant" with the specification "Silicon Dioxide 58%, Calcium Chloride 18%, Aluminum Oxide 8%, Dysprosium Oxide 0.15%" falls within the scope of the controlled item "mixture of dysprosium oxide".

③ A "catalyst raw material" with the specification "Water 90%, Zirconium Oxide 5%, Yttrium Oxide 0.5%" falls within the scope of the controlled item "mixture of yttrium oxide".

3. How is the control scope of "permanent magnet materials" defined?

Primary processed products formed by further simple processing of samarium- cobalt permanent magnet materials, terbium-containing neodymium-iron-boron permanent magnet materials, and dysprosium-containing neodymium-iron-

boron permanent magnet materials, such as sheets, tiles, rings, and related

magnetic assemblies, fall within the control scope. These may involve various

names such as magnetic steel, magnetic rings, and magnets. Deeply processed electronic components (e.g., motors) or electronic products (e.g., speakers,

headphones, etc.) do not fall within the control scope.

Furthermore, rare earth downstream functional materials such as phosphors,

catalytic materials (e.g., "automotive catalysts"), crystal materials (e.g.,

"lutetium yttrium silicate optical crystals"), and ceramic materials (e.g.,

"yttrium-zirconium alloy", "zirconia ceramic blocks for all-ceramic dentures",

"ceramic whitening agents", "thermal spray powders", "yttria-stabilized zirconia powder") are not within the control scope of medium and heavy rare earth

items. If items containing both yttrium and zirconium elements meet the

specifications of items controlled under entries such as 1C234 of the Dual-Use Items Export Control List, they shall be managed according to the relevant dual- use item requirements. "Gadobutrol hydrate" and "Gadoteric acid meglumine

salt" are not within the control scope of medium and heavy rare earth items.