【Graphite】Ministry of Commerce and Other Four Departments: Updated Announcement on Graphite Export Controls!

On November 15, the Ministry of Commerce, the Ministry of Industry and Information Technology, the General Administration of Customs, and the State Cryptography Administration jointly issued an announcement regarding the Export Control List of Dual-Use Items of the People's Republic of China, which will come into effect on December 1, 2024.

Simultaneously, 11 previous announcements will be repealed, including:

• Announcement No. 23 of 2023 by the Ministry of Commerce and the General Administration of Customs (Announcement on Export Control of Gallium and Germanium-related Items);

• Announcement No. 39 of 2023 by the Ministry of Commerce and the General Administration of Customs (Announcement on Temporary Export Control Measures for Graphite Items);

• Announcement No. 31 of 2024 by the Ministry of Commerce, the General Administration of Customs, and the Central Military Commission Equipment Development Department (Announcement on Optimizing and Adjusting Export Control Measures for Unmanned Aerial Vehicles).

The Export Control List of Dual-Use Items includes 10 categories, such as special materials and related equipment, chemical products, material processing, electronics, telecommunications and information security, sensors and lasers, marine, aerospace, and propulsion. These involve graphite and its products, carbon fiber-reinforced composites, carbon-carbon composites, ultra-high molecular weight polyethylene, etc. Below are selected excerpts for reference and study purposes:

Category 1: Special Materials, Related Equipment, Chemical Products, Microorganisms, and Toxins

1A Systems, Equipment, and Components
1A202 Tubular composite structures with both of the following characteristics:
a. Inner diameter of 75–400 mm;
b. Made of any “fiber or filament materials” controlled under item 1C210.a or resin-impregnated carbon fiber materials controlled under item 1C210.c.

1C Materials
1C102 Pyrolytic carbon-carbon composites subjected to multiple impregnations.
1C107 Ceramic composites with a "dielectric constant" of less than 6 within the frequency range of 100–10,000 Hz.
1C108 Graphite and its products:
a. Artificial fine-grained bulk graphite with all the following properties measured at 20°C:

1. Density greater than 1.72 g/cm³;

2. "Tensile failure strain" greater than or equal to 0.7%;

3. "Thermal expansion coefficient" less than or equal to 2.75×10⁻⁶/°C.
b. Artificial graphite materials and products with all the following properties:

4. Purity greater than 99.9%;

5. Flexural strength greater than 30 MPa;

6. Density greater than 1.73 g/cm³.

c. Natural flake graphite and its products (including spherical graphite, expanded graphite, etc.).

1C210 “Fiber or filament materials,” prepregs, and composite structures:
a. Carbon or aramid “fiber or filament materials” with either of the following characteristics:

1. “Specific modulus” greater than or equal to 1.27×10⁷ m;

2. “Specific tensile strength” greater than or equal to 2.35×10⁵ m.
Note: Item 1C210.a does not control aramid “fiber or filament materials” with 0.25% or more (by weight) ester-based surface modifiers.
b. Glass “fiber or filament materials” with both of the following characteristics:

3. “Specific modulus” greater than or equal to 3.18×10⁶ m;

4. “Specific tensile strength” greater than or equal to 7.62×10⁴ m.
c. Continuous filaments, rovings, yarns, or tapes no wider than 15 mm (prepregs), made from carbon or glass “fiber or filament materials” controlled under items 1C210.a or 1C210.b and impregnated with thermosetting resin.

1C901 Ultra-high molecular weight polyethylene fibers and products:
a. Ultra-high molecular weight polyethylene fibers with all the following properties:

1. Breaking strength greater than or equal to 40 cN/dtex;

2. Initial modulus greater than or equal to 1600 cN/dtex;

3. Untwisted.
b. Non-pressed soft unidirectional fabric laminates made from ultra-high molecular weight polyethylene fibers with an areal density of less than or equal to 5.3 kg/m², exhibiting a V50 ballistic limit greater than or equal to 700 m/s for 1.1 g standard fragment simulation projectiles (FSP), tested per Appendix B of GJB4300A-2012.

Category 2: Material Processing

2C Materials
2C901 Diamond window materials:
a. Curved diamond window materials.
b. Flat diamond window materials with all the following properties:

1. Single crystal or polycrystal with a diameter greater than or equal to 3 inches;

2. Visible light transmittance greater than or equal to 65%.

Category 9: Aerospace and Propulsion

9C Materials
9C110 Structural composite materials, including various composite structural components, laminates, and products reinforced with fibers or filaments and made with resin or metal matrices, with “specific tensile strength” greater than 7.62×10⁴ m and “specific modulus” greater than 3.18×10⁶ m:
a. Polyimide composites;
b. Polyamide-based composites;
c. Polycarbonate composites;
d. Quartz fiber-reinforced composites;
e. Carbon fiber-reinforced composites;
f. Boron fiber-reinforced composites;
g. Magnesium metal matrix composites;
h. Titanium metal matrix composites.

9C116 Ceramic or ablative thermal protection materials:
a. Ceramic thermal protection materials.
b. Ablative thermal protection materials.

(Additional categories omitted for brevity.)

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