A ban is the weakest instrument in the export control toolkit. It is visible, it is dated, it is reported on the day it is announced, and it can be repealed as publicly as it was imposed. A licensing regime is a far harder wall, and almost nobody outside the affected trade notices when one is built.
The last two years of Chinese mineral export policy are a demonstration of that principle. The bans made headlines. The licensing did the work.
The suspension that is not a repeal
China's export ban on gallium, germanium, antimony and superhard materials to the United States is suspended until 27 November 2026, according to Fastmarkets. Licensing still applies.
Those two sentences need to be read together, because the first is what gets reported and the second is what determines whether a cargo moves. A suspended ban means the categorical prohibition is not currently in force. It does not mean the material flows. Every shipment still requires a licence, which means an application, a stated end user, a stated end use, and a decision by an administrative body under no obligation to explain itself or to decide within any particular period.
It is also a suspension with an expiry date on it, which is a different thing from a repeal. A trader planning a shipment that lands in December 2026 is planning against a regime whose legal basis reverts on 27 November unless something changes. That is not a risk that can be insured or hedged. It can only be contracted around, and most standard sale contracts do not contemplate it.
What a licence does that a ban does not
The functional difference is discretion.
Under a ban, everyone in the market knows the position. Nobody ships, prices reprice to reflect the absence of that origin, buyers qualify alternatives, and the trade reorganises around a known constraint that applies to every competitor equally.
Under a licence regime, the position is unknown and, more importantly, it is unknown differently for each applicant. One party's licence is granted in six weeks. Another's sits. Neither knows what the other received, because there is no publication and no docket. Volumes can be throttled to any level between zero and the previous norm, adjusted continuously, without any announcement at all. A market cannot reprice around a constraint it cannot observe.
From 1 January 2026, China's Export Licensing Catalogue was extended to include samarium, gadolinium and lutetium compounds, and silver. That extension was not a ban and did not read like one.
The whitelist
The most restrictive change we are aware of is also the one that has received the least attention. Tungsten, antimony and silver have been moved to a state trading system under which only approved enterprises may export. The approved counts for 2026 and 2027 are 44 firms for silver, 15 for tungsten and 11 for antimony.
We hold that with medium confidence. It comes from trade press rather than from a published legal instrument we have been able to read, and it needs corroboration before anyone builds a contract around it. We are publishing it with that caveat attached because the commercial implication, if it is accurate, is larger than anything else described here.
There is a door, and it is worth being accurate about it, because the claim that the list is closed circulates widely and is wrong. The Ministry of Commerce publishes qualification thresholds for new applicants. Tungsten requires a three year average export supply of at least 2,000 tonnes of ammonium paratungstate equivalent, a bank credit line of 200 million renminbi and ISO 9000 and ISO 14000 certification. Antimony requires a three year average of at least 7,000 tonnes of refined antimony or 5,000 tonnes of antimony oxide on the same certification basis.
Read those thresholds again and notice what they actually do. They are not a prohibition. They are a scale test, applied to an industry the state has already concentrated. A firm large enough to clear them is, almost by construction, a firm already inside the system. The door is real, it is published, and it is set at a height that admits very few who were not already there. That is a more durable instrument than a closed list, because it is defensible in any trade forum as an ordinary qualification requirement rather than as a restriction.
What the antimony price shows
Antimony reached a record 59,750 dollars per tonne on 4 July 2025 on Fastmarkets' assessment, and has fallen a long way from that peak since. A figure of roughly 24,588 dollars per tonne for China in February 2026 circulates, which we have not been able to confirm against a named assessor, so we give it as a number in circulation rather than as an assessment.
A price that spikes to a record and then gives back the majority of the move inside eighteen months is not describing a permanent supply loss. It is describing a market that panicked, drew down inventory, found substitutes or demand destruction, and re-equilibrated at a level still far above where it began. That is the characteristic signature of an announcement driven move rather than a structural one.
The lesson for anyone trading a controlled mineral is about timing rather than direction. The largest move happens at the announcement, when the market is pricing the maximum plausible interpretation of a policy nobody has yet operated under. The eventual level is set months later by how the licensing is actually administered, which only becomes apparent from cargo flows. Selling into the announcement and buying into the administration is, in most control episodes we have watched, the correct sequence, and it is the opposite of what the headlines invite.
The figures we are not going to print
There are tungsten numbers circulating for 2026, covering the percentage move since January, concentrate in dollars per metric tonne unit, APT and powder.
We have seen them and we are not publishing them. The source we found them in is a promotional investor outlet with an interest in the direction of the price, and we have not been able to verify any of the figures against an assessment we would rely on. A tungsten price is a commercial input. Publishing an unverified one because it is the only one available is worse than publishing nothing, because a reader has no way to distinguish a figure we found from a figure we checked. What we will say is that tungsten sits in the group of materials affected by the state trading change described above, which is the part of the picture that does not depend on a price at all.
What the West has committed to, which is less than it sounds
The response from importing blocs is frequently described in terms that overstate its force.
The EU Critical Raw Materials Act, proposed on 16 March 2023 and adopted as Regulation (EU) 2024/1252 on 11 April 2024, sets 2030 benchmarks of 10 per cent of consumption from EU extraction, 40 per cent from EU processing and 25 per cent from recycling, with no more than 65 per cent of consumption of any strategic raw material coming from a single third country. These are targets. They are non-binding. No member state or company is obliged to meet them and no penalty attaches to missing them. They are a statement of direction, and they are useful as a statement of direction, but a supplier who reads the 65 per cent figure as a guaranteed quota available to non-Chinese origins has misread the instrument.
The United States position is similarly less concluded than the vocabulary suggests. A Section 232 investigation into processed critical minerals and their derivative products was initiated on 22 April 2025 under Executive Order 14272, with the Federal Register notice published on 25 April 2025. Proclamation 11001 followed on 14 January 2026. No tariffs were imposed. The proclamation directed negotiations instead, with a report back at 180 days, falling around 13 July 2026, the outcome of which we have not been able to verify. The administration reserved minimum import prices as a possible future remedy. This account follows Covington's analysis.
A reserved remedy is worth more attention than an imposed one, for the same reason a licence is worth more attention than a ban. Minimum import prices, if they were ever introduced, would set a floor below which imported processed mineral could not enter the United States regardless of world price. For a low cost producer that is not protection, it is exclusion from the arbitrage that makes him low cost in the first place. It sits on the table, undated, available.
The pattern across all three jurisdictions is the same and it is the thing worth carrying away. The instruments that move the most money are the ones that create discretion rather than the ones that create rules: a licence rather than a ban, a whitelist rather than a licence, a reserved remedy rather than a tariff. Each is harder to observe than the last, each is harder to plan against, and each generates a smaller headline. A seller who tracks announcements is tracking the least consequential layer of the system.