China export controls are about to return to the buyer’s calendar. China suspended six export control announcements from November 7, 2025 until November 10, 2026, according to Pillsbury Winthrop Shaw Pittman. That window closes in a few weeks.
However, the date has moved. Treasury Secretary Scott Bessent said on September 23, 2026 that both governments would extend the Busan agreement by two months, to January 10, 2027, as reported by the National Law Review. The extension had not yet appeared in a Federal Register notice. In the sources we read, there is no sign that China has published an instrument extending its own suspension.
Therefore, a buyer with magnets, batteries or rare earth components in the bill of materials should not treat the extension as settled. This article covers what remains controlled, what to request from your manufacturer now, and how to verify the answers.
What China export controls paused, and what they did not
The suspended announcements are dated October 9, 2025. They cover rare earth equipment and items, lithium battery materials and graphite anodes, synthetic diamonds, and foreign made products with Chinese content, per Pillsbury. In addition, a pause is not a repeal. Pillsbury notes that while enforcement is paused, the legal framework remains intact.
Some controls were never suspended. Dual-use bans on US military end users remain, and so do the 2025 controls on tungsten, tellurium and other rare earths. East Asia Brief adds that seven heavy rare earths under Announcement 18 of 2025 stay under continuous control. It also reports that some products face review periods of 45 business days.
Buyers often confuse these two groups. For example, a supplier who says the controls are paused may be right about one announcement and wrong about another. The same source says that without a renewal before November 10, the restrictions reactivate automatically. That article predates the extension news, so read it as the baseline rule.
Plan for three scenarios, not one
Bessent also expressed uncertainty about whether a broader deal will arrive before January 10 or whether the truce will need another extension, according to IndexBox. The extension is temporary, so it can repeat or fail. Plan for all three outcomes:
- The extension is formalized. Orders continue, but your documentation should be ready anyway.
- Another extension follows in January. You get more time, not more certainty.
- The pause lapses. The restrictions return, and review periods such as 45 business days start to matter for your lead times.
The TariffsTool summary confirms the new date and the stated scope. However, it is a secondary source. Cite the Bessent statement, not an official Chinese text, until one exists.
Composition is the question: the 0.1% rule
One secondary source, Carra Globe, describes MOFCOM Notice 61 as requiring a Chinese licence for products made outside China that contain Chinese origin rare earths at 0.1% or more of product value. It says the trigger sits at component level, not at finished product level. It lists NdFeB magnets, hard drives and cooling systems among the affected items.
However, another source we consulted gave different dates and a weight based criterion, so we did not rely on it. Therefore, check this rule against the official MOFCOM text before you act on it. This article is informational and is not legal or customs classification advice.
The practical point holds either way. If the trigger is tied to components, the only party who knows what is inside your product is the manufacturer.
What to ask the manufacturer about China export controls
Send a short written questionnaire to every supplier whose product has magnets, battery cells or rare earth components. Ask for:
- A bill of materials with component level detail, marking every magnet, battery and rare earth containing part.
- A written declaration of the origin of those materials.
- Which components, if any, the supplier believes need an export licence, and who would apply.
- Whether the supplier has applied for a licence before, and how long it took.
- Alternative sources for the critical components.
- A commitment to notify you in writing if the composition of any part changes.
In addition, agree in writing how a regulatory change affects price and lead time. Ask for payment terms with safeguards instead of a full advance payment.
Verify the answers instead of collecting them
A document is only as good as the party who signs it. A trading company that resells another factory’s goods can fill in a questionnaire without knowing what goes into the product. For that reason, the first check is whether you are talking to the manufacturer.
This is where on the ground presence matters. BiiLinx works with its own team and offices in Shenzhen, so someone can walk into the plant, compare the bill of materials against what is on the line, and ask the production manager the follow up questions. A forwarded email cannot do that.
What to do this week
First, list the products in your catalogue that contain magnets, batteries or rare earth parts. Second, send the questionnaire above to those suppliers. Third, treat November 10, 2026 as a risk date until both governments publish the formal text, and confirm on the official MOFCOM website whether the extension has been published.
If you need help filtering manufacturers, visiting a plant or supporting a negotiation, see our consulting services, learn about the team, or contact us. We do not promise factory prices or negotiation outcomes. We help you buy with verified information.