MOFCOM Export Control List: European Entities and Supply Risk

China’s export controls create two distinct exposures for European companies: restrictions attached to named entities and licensing requirements attached to materials, technology and transactions. MOFCOM Announcement No. 30 of 24 July 2026 names companies in Germany, France and the Netherlands; rare-earth controls can also affect businesses without an individual designation.

A supplier-name screening result won’t settle whether a European rare-earth shipment needs Chinese authorisation. The relevant questions include the controlled item, Chinese-origin content, production technology, end user and transaction route. These tests can reach a company that doesn’t appear on an entity list. MOFCOM Notice No. 61 and the October 2025 legal briefing describe that distinction.

Materials Dispatch separates the following ten points into legal status, product and technology triggers, country-level entries and documentation requirements. The five-country comparison uses the same criteria throughout: entities named in Announcement No. 30, the applicable restriction, broader material exposure and the relevant operational record. It is not a ranking of national vulnerability or a complete roster of European designations.

Key Takeaways

• Announcement No. 30 imposes counterparty-specific restrictions on dual-use supplies; these differ from the rare-earth licensing framework.
• The country entries below distinguish named entities from sector exposure. Neither a company’s nationality nor its absence from that announcement resolves an item-based licensing question.
• The October 2025 rare-earth announcements require notice-specific treatment alongside the subsequent suspension and the shipment date.

1. The effective date comes before the shipment decision

The October 2025 announcements and the rules governing a later shipment aren’t interchangeable. China introduced rare-earth restrictions on 4 April 2025, announced an expanded framework on 9 October, and set separate implementation dates for additional materials and foreign-made products. A subsequent MOFCOM information page dated 6 December 2025 describes a one-year suspension concerning rare earths, super-hard materials and other strategic resources.

That suspension is not a basis for treating every earlier rare-earth restriction as withdrawn, or every October measure as operative. Its application depends on the specific control notice and the suspension instrument. The relevant comparison is the item, the notice’s effective and suspension dates, and the export date—not simply whether the supplier is European.

Operational record: A control classification needs the applicable notice, effective date and suspension treatment. An October announcement alone does not determine the licensing position for a later shipment.

2. Entity restrictions and item controls are separate mechanisms

The phrase “MOFCOM export control list” can obscure distinct mechanisms. Controlled-item rules regulate goods, technologies and transactions. Entity-based export restrictions attach to named counterparties, while China’s Unreliable Entities List is a separate instrument. A European importer, manufacturer or distributor can encounter item-based controls without an individual designation. Notice No. 61 addresses overseas transactions involving specified rare-earth items.

MOFCOM Announcement No. 30, dated 24 July 2026, imposes export-control restrictions on 14 named entities. It prohibits export operators from supplying dual-use items—goods, software or technology with civilian and military applications—to those entities. It also prohibits overseas organisations and individuals from transferring or providing Chinese-origin dual-use items to them, requires related activities already under way to cease immediately, and permits an exporter to apply to MOFCOM in genuinely exceptional circumstances.

The April 2025 rare-earth restrictions covered samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium, alongside specified related products. The October policy update described five further elements—holmium, erbium, thulium, europium and ytterbium—scheduled for restrictions from 8 November 2025. Those announcements require separate treatment from the later suspension. European Parliament briefing; October policy update.

Operational record: Entity screening and item classification answer different questions. A name match requires examination of the designation’s restrictions; a clean name check does not resolve a magnet or compound classification.

3. The 0.1% test is about value, not weight

The October framework described a licensing trigger for foreign-made products containing at least 0.1% Chinese-origin specified rare-earth content by value, scheduled to apply from 1 December 2025. The GvW legal briefing explains this extraterritorial scope. Its application to a shipment depends on the relevant notice’s subsequent suspension treatment.

A bill of materials reporting grams of rare earths doesn’t, by itself, answer a value-based test. Nor does a European country-of-manufacture declaration establish the origin of an embedded magnet. For a covered assembly, the unresolved dependency can sit several supplier tiers below the exporter.

Operational record: Material-origin documentation and the applicable valuation methodology address this test. A mass percentage cannot substitute for the stated value threshold.

4. Chinese technology can matter when material comes from elsewhere

Non-Chinese feedstock isn’t necessarily the end of the analysis. The announced framework also captures certain foreign-made goods produced using Chinese-origin rare-earth technology. That creates a separate exposure from the content threshold: changing the material supplier may leave the production-process connection intact. GvW’s briefing describes both tests.

For processing and magnet-production projects, material-origin records and technology-provenance records therefore serve different purposes. A supplier statement covering ore or oxide origin doesn’t necessarily address a Chinese technology licence or covered production know-how.

Operational record: The technology’s scope and origin require separate documentation from the feedstock’s origin, together with the operative treatment of the relevant control notice.

5. Germany: three named entities alongside component-level exposure

• Named entities: Sindlhauser Materials GmbH, Rheinmetall AG and Antraco Chemie-Handelsgesellschaft mbH appear in MOFCOM Announcement No. 30 of 24 July 2026.
• Restriction: The announcement’s dual-use supply prohibition and restrictions on overseas transfers of Chinese-origin dual-use items apply to these named counterparties.
• Operational record: Exact legal-entity identity, item classification, Chinese origin and transaction records address the designation; component specifications and material-origin declarations address separate rare-earth controls.

For German manufacturers, importers and distributors more broadly, potential exposure includes controlled rare earths, permanent magnets, rare-earth-containing products and Chinese rare-earth technology. The bottleneck isn’t necessarily importing a metal directly: it can be identifying controlled content within a purchased component. The European legal briefing also describes potential obligations for transactions performed outside China.

The named restrictions do not designate German industry as a whole. Equally, the announcement does not quantify the three companies’ rare-earth purchases or establish which individual materials each receives.

6. France: three named entities and separate end-use requirements

• Named entities: InPACT S.A., III-V LAB and Cavok UAS appear in MOFCOM Announcement No. 30 of 24 July 2026.
• Restriction: The same dual-use supply prohibition and restrictions on overseas transfers of Chinese-origin dual-use items apply.
• Operational record: Exact legal-entity identity, item classification, Chinese origin and transaction records address the designation; end-user and end-use documentation address any separate licensing requirement.

French aerospace, defence, healthcare, automotive, energy and electronics supply chains encounter the item-based framework where controlled materials enter their products. Licence applications can require end-user, end-use and supply-chain information, making the eventual application relevant alongside the material classification. MOFCOM’s notice sets out the overseas licensing mechanism; the European Parliament text addresses industrial and confidentiality concerns.

A Chinese dual-use item export permit is an authorisation mechanism, not an automatic prohibition on French companies generally. That distinction does not displace the specific restrictions on the three named entities. For other transactions subject to licensing, an incomplete end-use dossier can leave authorisation unresolved even after the material has been classified.

7. Netherlands: one named entity and a separate equipment test

• Named entity: IHC Merwede Holding B.V. appears in MOFCOM Announcement No. 30 of 24 July 2026.
• Restriction: The same dual-use supply prohibition and restrictions on overseas transfers of Chinese-origin dual-use items apply.
• Operational record: Exact legal-entity identity, item classification, Chinese origin and transaction records address the designation; equipment specifications address separate production-equipment controls.

Dutch advanced-manufacturing and electronics businesses face a broader question than whether a finished product contains rare earths. The October measures also addressed rare-earth production and processing equipment, plus related materials. Equipment classification and embedded-material classification are separate routes into the control framework. October policy update; GvW briefing.

A magnet-only questionnaire does not address covered processing equipment: the equipment’s technical function and notice-specific classification are separate considerations. This broader sector exposure should not be treated as a description of IHC Merwede Holding B.V.’s material purchases.

8. United Kingdom: no entry in Announcement No. 30

• Named entities: Announcement No. 30’s 14-entity list contains no UK entity.
• Restriction: That announcement does not establish a UK designation. Item-based controls can nevertheless apply to covered transactions involving UK businesses.
• Operational record: Item classification, Chinese origin, technology provenance, end use and the onward transaction route address this separate exposure.

UK companies operate outside the EU customs framework, but that doesn’t remove potential Chinese licensing obligations for controlled Chinese-origin goods or covered foreign-made products. A UK intermediary handling a relevant item needs a transaction analysis distinct from its domestic export-control assessment. Notice No. 61 and the legal briefing describe the overseas reach.

Origin, classification and end-use records remain relevant through a UK transaction. Crossing into a different customs jurisdiction does not, by itself, resolve the item’s Chinese export-control status.

9. Sweden: no entry in Announcement No. 30

• Named entities: Announcement No. 30’s 14-entity list contains no Swedish entity.
• Restriction: That announcement does not establish a Swedish designation. Separate item and technology controls can affect covered supply-chain transactions.
• Operational record: Item classification, Chinese material origin, processing-technology provenance and finished-component records address this exposure.

Swedish mining, industrial-equipment, automotive, defence and clean-energy supply chains illustrate why a European resource base and an independent finished-material supply chain aren’t equivalent. Potential exposure remains where covered Chinese-origin materials or technology enter processing or component production. The European Parliament text identifies disruption risks across wind power, automotive, healthcare, space and defence; the legal briefing explains the origin and technology triggers.

A diversification claim becomes operationally meaningful when it addresses covered processing technology and finished components, not merely the location of the mineral resource.

The country distinctions below concern industrial applications, not different Chinese content thresholds or a comparative exposure ranking:

Country	Relevant item-based exposure	Decisive operational record
Germany	Magnets and rare-earth-containing components	Component classification and material origin
France	Controlled inputs in sensitive end uses	End-user and end-use dossier
Netherlands	Covered processing equipment and manufactured goods	Equipment specifications and item classification
United Kingdom	Overseas transfers of covered items	Origin and transaction-route records
Sweden	Materials and technology across industrial supply chains	Separate feedstock and technology provenance

10. Licence documentation can become a confidentiality bottleneck

Once a transaction falls within an operative licensing requirement, information availability becomes a supply-chain constraint. The European Parliament text identifies concerns about sensitive information disclosed to Chinese authorities during licensing. An exporter may need details held by a downstream customer rather than by the immediate purchaser.

This is a different failure mode from insufficient physical supply: material can exist while the authorisation dossier remains incomplete. Contract provisions covering end-use statements, onward transfers and disclosure responsibilities therefore affect whether the licensing process can proceed. Chinese authorisation also remains separate from obligations under the EU dual-use regime.

Operational record: The licensing dossier connects the applicable notice and shipment date to the item, origin, technology, end user and disclosure permissions. For a designated counterparty, the separate entity restriction and any exceptional-application provision remain relevant; ordinary licensing documentation does not replace that analysis.

Conclusion

MOFCOM’s named-entity restrictions and rare-earth item controls create different constraints on European supply chains. Announcement No. 30 identifies specific counterparties in Germany, France and the Netherlands, while broader licensing exposure depends on the goods, technology, transaction and operative dates. The market implication is that available material is not necessarily transferable material: counterparty restrictions, suspension scope and documentation can each determine whether supply reaches the customer.