---
type: source
title: "China's NdFeB Export Controls Are Two-Tiered: April 2025 Controls Still Active; October 2025 Expansion Suspended Until November 2026"
author: "Multiple: CSIS, Clark Hill PLC, Arnold Magnetic Technologies, East Asia Forum, China Briefing, Fortune"
url: https://www.csis.org/analysis/chinas-new-rare-earth-and-magnet-restrictions-threaten-us-defense-supply-chains
date: 2026-05-07
domain: manufacturing
secondary_domains: [robotics]
format: research-synthesis
status: null-result
priority: high
tags: [China, NdFeB, rare-earth, export-controls, humanoid-robots, Optimus, supply-chain, trade-deal, Xi-Trump, dysprosium, terbium, manufacturing]
intake_tier: research-task
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

**China's Rare Earth Export Control Architecture — Full Two-Tier Structure:**

**Tier 1 — April 4, 2025: Controls on 7 heavy rare earth elements (STILL IN EFFECT)**
Elements covered: Samarium (Sm), Gadolinium (Gd), Terbium (Tb), Dysprosium (Dy), Lutetium (Lu), Scandium (Sc), Yttrium (Y)

**Critical point:** Dysprosium (Dy) and Terbium (Tb) are the core additives in high-performance sintered NdFeB magnets — the specific type required for humanoid robot actuators. An Optimus robot needing ~3.5 kg of high-performance NdFeB will contain Dy and Tb for high-coercivity performance in small high-torque actuators. These April 2025 controls remain FULLY IN EFFECT as of May 2026, including through and after the Xi-Trump trade deal.

**Tier 2 — October 9, 2025: Expanded controls on additional 5 elements + "parts, components and assemblies" (SUSPENDED until November 10, 2026)**
Additional elements: Holmium, Erbium, Thulium, Europium, Ytterbium
Also included: "Parts, components and assemblies" incorporating rare earth elements — broader category that would have dramatically impacted supply chains

**The Xi-Trump deal (October 30, 2025):** China agreed to suspend the October 9, 2025 expansion for one year (until November 10, 2026). This was part of a broader tariff rollback. The White House announced "general licenses valid for exports of rare earths, gallium, germanium, antimony and graphite for the benefit of U.S. end users."

**What the deal did NOT suspend:** The April 2025 controls on Dy, Tb, and the other 7 heavy rare earths. These remain under individual export licensing requirements. Musk's April/May 2026 statements about seeking export licenses and Optimus production delays due to a "magnet issue" are consistent with the April 2025 controls still being active.

**The "paperwork rationing" mechanism (East Asia Forum analysis):** Even with general licenses, China uses administrative delays in the licensing process to effectively ration rare earth exports. License applications typically take 20-30 working days but US-related applications involving national security-sensitive end uses may take 6+ months. This creates a de facto quota even when formal controls appear to allow exports.

**The magnet technology export ban (NOT suspended):** The ban on exporting magnet production TECHNOLOGY (process know-how, equipment, manufacturing methods) was NOT covered by the trade deal. US companies can import finished NdFeB magnets (subject to April 2025 licensing), but cannot acquire the knowledge to manufacture them domestically. This is the structural constraint that perpetuates long-term dependency regardless of current trade negotiations.

**Supply reality for Optimus:**
- High-performance NdFeB (with Dy/Tb): Still under April 2025 export licensing
- Musk confirmed in April-May 2026: seeking Chinese export license; "not for military use, just for humanoid robots"
- Non-China ceiling through 2029: Japan ~4,500 tonnes/year NdFeB; USAR targeting 10,000 tonnes non-China NdFeB by 2029

## Agent Notes

**Why this matters:** The May 5/6 analysis concluded the rare earth constraint is "structural through 2029." Today's finding adds a critical nuance: the constraint operates through TWO mechanisms, not one — and the Xi-Trump deal only partially addressed the second tier (October expansion), leaving the first tier (April controls on Dy/Tb) fully in place. The KB currently treats this as a single constraint; it needs to distinguish the tiers.

**What surprised me:** The disconfirmation search on "China strategic delay vs bureaucratic friction" found a clear answer: it's BOTH. The April 2025 controls are genuinely strategic (timed with US tariffs, targeted at critical materials). But the Xi-Trump deal shows China is willing to suspend at least some controls when offered sufficient trade concessions. This is not pure antagonism — it's leverage, not blockade.

**What I expected but didn't find:** Clear evidence that China granted (or denied) Tesla's specific export license application. The Musk statements confirm the license is being sought, but no reported outcome as of May 2026.

**KB connections:**
- Directly extends: existing China rare earth archive (2026-05-05) — that archive was archived before the two-tier structure was clear
- Relevant to: Belief 11 (robotics is binding constraint) — the specific mechanism of the hardware constraint is the April 2025 Tier 1 controls on Dy/Tb, not the suspended October controls
- New pattern: "China as competitor-controller" — China's strategic use of export licensing is sophisticated leverage, not simple denial; the willingness to negotiate (Xi-Trump deal) shows it's calculated, not reflexive

**Extraction hints:**
1. "China's rare earth export controls on humanoid robot-critical materials operate through two tiers: April 2025 controls on dysprosium and terbium (still in effect, requiring individual export licenses) and October 2025 expanded controls (suspended until November 2026 under the Xi-Trump trade deal)"
2. "China's magnet production technology export ban — covering manufacturing know-how and equipment rather than finished magnets — creates a structural constraint on US rare earth manufacturing independence that persists regardless of trade deal outcomes on finished product exports"

## Curator Notes (structured handoff for extractor)

PRIMARY CONNECTION: Existing archive 2026-05-05-china-rare-earth-export-controls-optimus-ndfeb-production-delay.md

WHY ARCHIVED: Critical nuance missing from the May 5 archive: the trade deal only suspended Tier 2 (October 2025 expansion), not Tier 1 (April 2025 Dy/Tb controls). Without this distinction, the constraint analysis is wrong — the Xi-Trump deal looks like it resolved the problem, when it only partially did.

EXTRACTION HINT: Do NOT extract a new standalone claim about the general China constraint (well-covered by May 5 archive). Extract specifically: (1) the Dy/Tb distinction (which chemicals are actually under active controls), and (2) the magnet technology ban (a separate constraint from the materials controls). These are genuinely new KB content.
