Every time a US-China truce headline lands, our compliance desk gets the same hopeful call: "the rare-earth controls are paused now, so my magnets ship freely, right." The honest answer is no, and the gap between that headline and what actually clears customs is where shipments get stuck. The controls that were suspended in late 2025 are mostly the US-specific ones on gallium, germanium and antimony. The licensing regime that stops the average magnet shipment was never suspended and is fully in force in 2026. GetTransport.com moves freight on the lanes that carry electronics, EV, and industrial cargo, so this is the operational read for a shipper or forwarder on keeping controlled rare-earth cargo moving, not a policy note on the trade war.
Three control tracks, three different clocks
The single most useful thing to understand is that China is running three separate export-control tracks, each on its own timeline. Trade press blends them, and that is how planners get the risk wrong. Here is how Pillsbury Law and White & Case lay them out:
| Track | What it covers | Status in 2026 |
|---|---|---|
| Dec 2024 (Announcement 46) | Ban on gallium, germanium, antimony, superhard materials to the US | Suspended 9 Nov 2025, reverts to licensing until 27 Nov 2026 |
| Oct 2025 (Announcements 55-62) | Five more heavy REEs (holmium, erbium, thulium, europium, ytterbium) + processing tech, a 0.1% de minimis and a 50% extraterritorial rule | Suspended 7 Nov 2025 until 10 Nov 2026 |
| April 2025 (Announcement 18) | Licensing on seven medium and heavy rare earths (samarium, gadolinium, terbium, dysprosium, lutetium, scandium, yttrium) and their compounds, alloys, metals and magnets | NEVER suspended, fully in force |
Read the table again, because two details drive every routing decision. First, the two suspended tracks expire on different dates that are 17 days apart, 10 November and 27 November 2026, so any contingency plan needs both diarized, not one. Second, and this is the part that catches importers, the April 2025 regime that covers dysprosium and terbium was never part of the truce. That is the one that licenses permanent magnets. The suspensions gave back gallium and germanium to US buyers under license; they did nothing for the magnet in your motor.
Why your magnet shipment is still license-controlled
The reason the April 2025 track bites so widely is chemistry. High-performance sintered NdFeB permanent magnets, the kind in EV motors, wind turbines, and industrial actuators, contain dysprosium or terbium to hold their magnetism at heat. Both elements sit on Announcement No. 18's list, so the magnet that contains them is license-controlled regardless of the headline truce. The control triggers on composition, not on the product name, which is where declarations go wrong.
For classification, sintered NdFeB magnets fall under HS 8505.11, and some national tariff schedules break out 8505.11.10 for magnets containing neodymium, praseodymium, dysprosium or samarium. But the HS code alone does not tell customs whether a license is needed. The trigger is composition, and in practice it runs on a 0.1% threshold: a magnet whose dysprosium or terbium content reaches 0.1% by weight, individually or combined, needs a license. The high-coercivity grades carrying the SH, UH, EH and AH suffixes are the ones that hold that content, so if your bill of materials shows one of those grades, treat the shipment as licensed until a composition certificate proves otherwise. Samarium-cobalt magnets are caught too, through the samarium listing, so this is not only an NdFeB question.
The license lead time is the real schedule risk
This is where freight plans break. Under China's Regulations on the Export Control of Dual-Use Items, which took effect on 1 December 2024, MOFCOM has a statutory target of 45 working days, roughly nine weeks, to decide a license, extendable, with no fixed deadline at all where a national-security review is triggered. That is the paper number. The reality, as the industry bulletin Duramag documents, is that heavy-REE approvals routinely run past 60 to 120 days, case by case, with no published procedure. Plan against the real window, not the statutory one, and do not book vessel or air capacity before the license is in hand.
There is one lever worth chasing. In December 2025 MOFCOM issued its first batch of general licenses, a multi-shipment, roughly year-long approval that lets a pre-cleared Chinese exporter ship to named, pre-vetted customers without seeking approval for each consignment. China Briefing reports the first went to major Chinese magnet makers including Jinli Permanent Magnet, Zhongke Sanhuan and Ningbo Yunsheng. It is not broadly available yet, but asking whether your supplier holds or can obtain a general license is the single biggest lead-time lever available in 2026. A supplier on a general license collapses the per-shipment wait; a supplier filing case by case leaves you exposed to the multi-month queue.
The documentation pack
The paperwork has escalated well beyond a simple end-user statement. Based on what Duramag and other trade sources describe, MOFCOM now expects the exporter to disclose the complete manufacturing value chain and the final application, plus authenticated customer information, detailed end-use descriptions, composition certificates, and technical descriptions of the goods. There is no single official form; the pack is assembled from those elements. Incomplete documentation is the most common avoidable cause of delay, so the pack has to be complete before the application goes in, not chased afterward. One screen that is never optional: the December 2024 prohibition on exporting any dual-use item to US military end-users or end-uses was never suspended, so any military nexus is a hard block that has to be cleared before you even quote.
A harder block arrived in mid-2026: the entity list
One change since the truce shifts the first question you have to ask. In June 2026 China added 10 US entities to its export-control list, including rare-earth supply-chain players such as MP Materials and USA Rare Earth. Unlike the licensing regime, this is close to a total prohibition on supplying dual-use goods to those named parties, and it applies across all countries and all persons, not just direct China-to-US shipments. That makes recipient screening the new first step, ahead of everything else: before you contract, check whether your end recipient or its affiliates sit on that list, because a match is not a license delay you can plan around, it is a hard block that will get the shipment stopped and can expose everyone in the chain. This sits alongside the December 2024 prohibition on supplying dual-use items to US military end-users, which was never suspended, so you are now screening for two separate hard blocks before you even reach the licensing question.
The mis-declaration trap
The tempting shortcut, declaring a Dy-bearing magnet as ordinary NdFeB to skip the license, is the fastest way to lose the cargo. According to industry reporting from magnet supplier Mainrich, a shipment declared as ordinary NdFeB was tested at Chinese customs, found to contain 1.2% dysprosium, reclassified as a controlled item exported without a license, and the exporter was fined several times the value of the cargo. We flag that specific case as single-source and illustrative rather than an official statistic, but the mechanism is well established: customs tests composition, and an under-declared controlled element turns a routine export into a seizure plus a penalty that dwarfs the freight. The defensive move is a composition certificate on file before booking, not a hopeful declaration.
What to do now
The operational playbook for 2026 comes down to treating these shipments as a licensing project attached to a freight move:
- Screen the end recipient and its affiliates against China's export-control entity list first: a listed party such as the US names added in June 2026 is a hard block, not a licensable shipment, so this check comes before quoting.
- Classify by composition, not by product name: any magnet whose dysprosium or terbium content reaches 0.1% by weight is license-controlled, which covers the SH, UH, EH and AH high-coercivity grades and samarium-cobalt magnets. Get a material composition certificate before you book.
- Build a realistic 10 to 12 week license window into every quote and schedule, because the 45-working-day statutory target routinely runs to two to four months, and do not commit freight capacity before the license issues.
- Assemble the full documentation pack up front: authenticated end-user and end-use statement, complete value-chain and final-application description, customer verification, composition certificates, and technical specs.
- Ask whether your Chinese supplier holds or can use a general license, since a pre-cleared multi-shipment approval removes the per-shipment queue entirely.
- Run a military-end-use screen before quoting, because that prohibition was never suspended and is a hard stop.
- Carry buffer stock on dysprosium and terbium-bearing inputs and qualify ex-China inventory now, because approvals are slow and volumes swing; duty-deferred staging can help, which we cover in our bonded warehouse duty-deferral guide.
- Diarize both cliffs, 10 and 27 November 2026: if the suspended tracks lapse, US-bound gallium, germanium and antimony plus the 0.1% and extraterritorial magnet rules snap back, and you need a routing and sourcing contingency dated to them.
Why you cannot just source elsewhere yet
The instinct to route around China runs into refining reality. According to the US Geological Survey, China accounts for roughly 98% of the world's refined gallium; germanium is lower, around 60 to 77% of refined output, so state those two separately rather than lumping them. On rare earths, the IEA puts China at about 60% of mine output but roughly 91% of refining and about 94% of sintered rare-earth magnet production in 2024, and the European Parliament notes the EU sources around 98% of its rare-earth magnets from China. The bottleneck is not ore, it is separation and magnet-making capacity, which take years to permit and qualify. Even after volumes recovered in 2025, the IEA notes European rare-earth prices ran up to roughly six times Chinese domestic levels. Alternative supply is a multi-year project, not a next-quarter routing change, which is exactly why the licensing discipline above is the near-term answer.
None of this sits in isolation from the wider trade fight. The same substantial-transformation and origin scrutiny we describe in our transshipment crackdown guide applies when Chinese-origin magnet content moves through a third country, and getting the Incoterms right decides who carries the license and clearance obligation, which we break down in our DDP versus DAP guide.
Frequently asked questions
Didn't the US-China truce lift the rare-earth controls?
Only partly. The suspensions cover the December 2024 ban on gallium, germanium and antimony to the US (now under licensing until 27 November 2026) and the October 2025 expansion (suspended until 10 November 2026). The April 2025 regime that licenses dysprosium, terbium and the magnets that contain them was never suspended and is fully in force in 2026, so most permanent-magnet shipments still need a license.
How long does a MOFCOM export license actually take?
The statutory target under the dual-use regulations is 45 working days, about nine weeks, and it can be extended with no fixed deadline where a security review applies. In practice, industry reporting shows heavy rare-earth approvals often run 60 to 120 days or more. Plan for a 10 to 12 week window and do not book freight before the license is issued. A supplier holding a general license can ship to pre-cleared customers without the per-shipment wait.
Which magnets are actually controlled?
Control triggers on composition, not the HS code. Sintered NdFeB magnets containing dysprosium or terbium are licensed, and in practice these are the high-coercivity grades with SH, UH, EH or AH suffixes. They classify under HS 8505.11 (some schedules use 8505.11.10), but the code alone does not decide the license, the dysprosium or terbium content does. Get a composition certificate before booking.
What happens if we declare a magnet as ordinary NdFeB to avoid the license?
Customs tests composition. If a shipment declared as ordinary NdFeB is found to contain a controlled element, it is reclassified as a controlled item exported without a license, seized, and penalized, with fines that industry reporting puts at several times the value of the cargo. Under-declaring dysprosium or terbium content is the specific failure mode that gets cargo stopped, so a composition certificate on file beats a hopeful declaration.