China Graphite Export Compliance & Dual-Use Controls Guide

Some graphite products do. Announcement No. 39 controls natural flake graphite and its products, including spherical graphite and expanded graphite. It also controls synthetic graphite materials and products when purity >99.9%, flexural strength >30 MPa and density >1.73 g/cm³ are all met simultaneously. The actual transaction must also be screened against other applicable control-list requirements, destination restrictions, end-user and end-use controls, and the risk-based licensing requirements for items outside the control list under Article 12 of the Export Control Law.

The graphite-specific scope in Announcement No. 39 includes specified high-purity, high-strength, high-density synthetic graphite materials and products, plus natural flake graphite and its products such as spherical graphite and expanded graphite. MOFCOM guidance also confirms that specified metal- or fiber-reinforced graphite packing, gaskets, composite sheets, lines and rings are outside this graphite-specific scope, subject to other applicable export-control rules.

After we receive a complete application package, we typically complete document review and formally submit the application to China’s Ministry of Commerce (MOFCOM) within 1–2 working days. MOFCOM’s statutory review period is 45 working days. An approval outcome is typically issued within 20–45 working days, depending on the review timeline of the competent authorities.

Dual-use export licenses generally follow the “one batch, one license” and “one license, one customs office” rules. Where split licensing is applicable, one application may request multiple licenses for planned split shipments, up to 12 batches under the current rules. The approved product, quantity, buyer, end user, end use and destination must remain within the license scope.

The filing package generally includes the application form, applicant identification information, the contract or agreement, a technical description or test report for the graphite item, end-user and end-use proof, importer/end-user information and other materials requested by the competent authority. The final end-user/end-use documents must match the actual transaction.

No. Under Announcement No. 39, synthetic graphite material/products fall within this graphite-specific criterion when purity >99.9%, flexural strength >30 MPa and density >1.73 g/cm³ are all met simultaneously. The transaction must still be screened against other control-list and end-use rules.

Expanded graphite is expressly included within the natural-flake-graphite product scope in Announcement No. 39. A finished flexible graphite sheet should therefore be screened from its actual material composition and product form rather than only from its marketing name. MOFCOM separately states that specified graphite products reinforced with metal or fibers are outside the graphite-specific scope described in that announcement, while other export-control rules can still apply.

QINGDAO ZHIRUITONG TECHNOLOGY CO., LTD. is the applicant/exporting entity for controlled transactions and submits the export-license application through the competent commerce-authority process. The overseas buyer, importer and final end user provide the transaction, company, end-user and end-use information needed to support the application.

Yes. We can review product parameters and help organize the commercial, technical, end-user and end-use information needed on the exporter side. Final classification, application acceptance and license decisions remain with the competent authorities.

Yes, when the purchasing plan is prepared in advance. The buyer and exporter/applicant can sign the relevant contracts/orders for the planned shipments and submit them together for the corresponding export licenses. Where split licensing is applicable, one application can cover up to 12 split batches. After those licenses are approved and issued, later shipments that remain within the already-approved contracts, products, quantities and license scope can use the corresponding issued licenses without repeating the export-license application process. New orders, changed specifications, changed end users/end uses, or shipments outside the approved scope require fresh screening and, where applicable, a new application.