China’s Ministry of Commerce has announced new export control measures on “dual-use products” on national security grounds, encompassing lithium ion batteries as well as cathode active materials (CAM) and anode active materials (AAM).

The restrictions were confirmed on the same day that Beijing escalated controls on rare earth elements and associated technologies, ahead of high-level trade talks between US President Trump and Chinese President Xi Jinping in the coming days. They follow existing controls on natural graphite, lithium iron phosphate (LFP) CAM, and lithium processing technologies. 

Scope of the restrictions

  • Cells and packs with a weight energy density ?300Wh/kg.
  • LFP CAM with a compacted density ?2.5g/cm³ and a gram capacity ?156mAh/g.
  • Nickel cobalt aluminium (NCA) and nickel cobalt manganese (NCM) precursor materials (pCAM).
  • Synthetic and natural graphite (AAM).
  • Associated processing technology and equipment for all of the above.

Taking effect from 8th November, companies wishing to export the covered products and materials will be required to obtain a licence, approval of which is at the discretion of China’s Ministry of Commerce. This process typically involves submitting detailed information including business scope, sales data, employee details, key customers, trade history, and an end-user certificate verifying the intended application.

Near to medium term outlook

Following the announcement of export controls on natural graphite in October 2023, a notable spike in exports was observed ahead of their implementation. Foreign companies reliant on Chinese imports increased shipments to build inventories and minimise near-term supply risks, leading to a temporary rise in export prices.

After implementation, export volumes declined sharply as exporters navigated the new licensing process — a slowdown that lasted two to three months. During this phase, Benchmark received reports, particularly for India and the US, indicating that some permit applications were not approved after 2-3 months, while exports to South Korea were approved quickly. This suggested a case-by-case approach to licensing decisions, despite public announcements that all countries would be treated equally.

The market eventually adjusted to the new regulatory norms as both exporters and importers familiarised themselves with the process.

A similar pattern is expected following the latest round of controls, although the scope of the impact will depend on how stringent the new licensing procedures are compared with those for graphite. Given that both are categorised as “dual-use” products, the severity of the restrictions is expected to be comparable, though the precise implications remain to be seen.

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