Since April 2025, almost every magnet enquiry we receive opens with a version of the same question: does this order need an export licence?
The honest answer is that nobody can answer it from the grade, the datasheet or the drawing. Export control of NdFeB magnets in China is determined by the chemical composition of the finished magnet — specifically by whether it contains dysprosium (Dy) or terbium (Tb). Everything else is a proxy, and every proxy has exceptions.
This article explains where the line actually sits, what is officially published and what merely circulates as folklore, why the same nominal grade can be controlled or uncontrolled depending on who manufactured it, and the four-step classification protocol we run before a controlled-looking order is allowed to ship.
If you want the wider framework first — what the control regime covers, how licensing works, and what it does to lead times — start with our buyer’s guide to China’s NdFeB export controls.
The Short Answer: Four Scenarios
| Your magnet | Dy / Tb present? | Export licence? |
|---|---|---|
| Sintered NdFeB, grades N / M / H / SH, from a producer that adds no Dy or Tb | No | No licence. Ships on standard lead time. |
| Sintered NdFeB, any grade, from a producer that uses Dy or Tb — including via grain boundary diffusion | Yes | Licence required, per shipment |
| SmCo magnets (SmCo₅ or Sm₂Co₁₇) | Yes — samarium is itself a controlled element | Licence required |
| Bonded or injection-moulded NdFeB | Depends on the magnetic powder used | Test the finished part, not the powder datasheet |
Two lines in that table cause almost all of the confusion in practice, and both are covered in detail below: the grain boundary diffusion case, and the fact that a grade name tells you nothing about chemistry.
What Announcement No. 18 Actually Controls
The controlling instrument is Announcement No. 18 of 2025, issued jointly by China’s Ministry of Commerce (MOFCOM) and the General Administration of Customs (GACC), effective 4 April 2025. It places seven medium and heavy rare earth elements under export control: samarium (Sm), gadolinium (Gd), terbium (Tb), dysprosium (Dy), lutetium (Lu), scandium (Sc) and yttrium (Y).
Three of those seven actually turn up in permanent magnets:
| Controlled element | Where it appears in magnets | Catalogue code |
|---|---|---|
| Samarium (Sm) | SmCo magnets (SmCo₅, Sm₂Co₁₇) — also present in some Gd-bearing 2:17 grades | 1C902 |
| Terbium (Tb) | NdFeB, added by alloying or by grain boundary diffusion | 1C904 |
| Dysprosium (Dy) | NdFeB, added by alloying or by grain boundary diffusion | 1C905 |
The light rare earths that form the backbone of every NdFeB magnet — neodymium (Nd), praseodymium (Pr) and cerium (Ce) — are not on the controlled list. This is the entire structural reason why HRE-free NdFeB remains freely exportable while heavy-rare-earth grades queue for licences.
Two practical notes. First, the control codes above sit in China’s dual-use export control catalogue; they are not the same thing as HS tariff codes, and a compliant declaration usually needs both. Second, control applies to the item, and for magnets the item is defined by what is inside the material — which is why a composition test, not a datasheet, is the deciding document.
The 0.1% Figure: What Is Official and What Is Not
A number circulates constantly in supplier emails, forwarder notices and industry posts: 0.1% Dy or Tb. It is worth being precise about its status, because a great deal of money and time hangs on it.
What is official: Announcement No. 18 defines the controlled scope by element and material. It does not publish a numeric content threshold for magnets. There is no line in the announcement that says “above 0.1% is controlled, below it is not.”
Where the number comes from: enforcement and testing practice. Customs-affiliated and accredited commercial laboratories have used roughly 0.1% Dy/Tb content as a practical screening benchmark — the level at which a magnet is treated, in practice, as a controlled item rather than as a trace contaminant. It is a working benchmark derived from how cases have been assessed, not a published figure.
The stricter reading: a number of freight forwarders advise that there is no de minimis at all — that if Dy or Tb is detected in a magnet, the shipment is a controlled item, full stop.
Both readings are defensible interpretations of an underspecified rule. What matters for a buyer is that the two readings have asymmetrical consequences:
- Follow the conservative reading and you may spend about four months on a licence you possibly did not strictly need.
- Follow the aggressive reading and you risk a penalty decision, a compliance record on your supplier, and a permanently elevated inspection rate on future shipments.
Our rule is simple and conservative. If a test report shows Dy or Tb above the laboratory’s limit of detection, we treat the order as controlled and licence it. A report that states the elements were not detected, at a documented detection limit, from an accredited laboratory, is the only basis on which we will ship without a licence. Nothing else — not a grade name, not a sales email, not a statement on an invoice — is a substitute.
Why the Grade Is Not the Classification
The most common piece of advice in the market is a rule of thumb: SH and below is safe; UH and above is controlled. As a description of typical production, it is roughly right, because heavy rare earths are added to raise coercivity at high temperature. As a classification rule, it fails in at least three ways.
1. Grain boundary diffusion breaks it. GBD puts terbium or dysprosium only at the grain boundaries rather than throughout the alloy. It is highly efficient: a small amount of Tb raises coercivity with little loss of remanence, which is exactly why so many producers use it. A magnet sold as SH from a factory that runs Tb-based GBD will contain terbium. A magnet of the same nominal grade from a factory that does not can be completely HRE-free. The grade name is identical; the customs classification is not.
2. Feedstock can carry contamination. Recycled or mixed feedstock is an increasingly common input, and trace heavy rare earths can follow it into a nominally HRE-free melt.
3. Some producers add Dy to mid-range grades for specific customers. If an application needs better thermal stability than the standard H grade provides, a supplier may quietly upgrade the chemistry rather than the grade designation.
Add these up and the conclusion is unavoidable: a datasheet describes magnetic performance, not chemistry. Datasheets are generated from typical values for a grade class. They are not batch analysis certificates, and they will not protect you in an audit.
The right question is not “what grade is it?” but “what is in this batch, and how do you know?”
A Four-Step Classification Protocol
This is the sequence we run on every order where Dy or Tb could plausibly be present.
| Step | What you obtain | Why it matters |
|---|---|---|
| 1. Composition disclosure | The element list from the melt or batch record | Establishes what was actually put in, rather than what the grade implies |
| 2. Process disclosure | A direct answer to: do you use grain boundary diffusion, and with which element? | The single most common hidden source of Dy and Tb |
| 3. Third-party testing | A composition test report from an accredited laboratory (CMA / CNAS in China, or a customs-affiliated testing centre) | The only externally verifiable evidence |
| 4. Written classification | A control classification statement from the supplier, referencing the test report | Ties the evidence to the shipment for customs and for your own audit file |
What a defensible test report must contain. A report that simply says “no dysprosium” is not enough. It needs:
- Sample identification traceable to the production batch or lot
- The test method used (ICP-OES for quantitative analysis; handheld XRF for screening)
- The limit of detection for Dy and Tb under that method
- The measured values, stated numerically
Our own practice is to have composition verified at a customs-affiliated testing centre in Ningbo, with the report travelling as part of the shipment documentation. Where the elements are present, the order enters the licensing route and takes about four months.
What Customs Actually Found: Three Published Cases
The abstract argument about thresholds becomes concrete when you read what enforcement decisions actually concluded. In 2026, Chinese customs published a series of decisions involving NdFeB magnets declared as ordinary, uncontrolled material where laboratory testing found dysprosium at 0.15%, 0.18% and 0.372%. In each case the shipment was classified as a controlled item.
Three things follow from that.
There is no practical de minimis. A tenth of a percent is not a rounding error in this context; it is the difference between a shipment and a penalty decision.
The most common failure is not smuggling — it is a careless declaration. Two patterns dominate: declaring a mixed shipment under a generic description such as “neodymium magnet” or “hardware”; and completing the element specification column of the declaration with a list of a dozen elements while omitting dysprosium. Under Chinese law, mis-declaration is assessed on whether the declaration was accurate, not on what the exporter intended.
Enforcement volume is not trivial. At least 211 export-control penalty decisions were published in 2025, and rare earth magnets have been among the most frequently penalized categories in the monthly data. This is an actively enforced regime, not a paper one.
Two Other Things That Can Stop a Magnet Shipment
Licensing is not the only gate, and an uncontrolled magnet is not an exempt magnet.
Inspection is a separate control. Chinese customs screens magnet cargo for possible Dy/Tb content, including with handheld XRF analysers that identify rare earth elements in seconds at the port. Screening is followed by elevated laboratory testing where results look anomalous. A shipment that needs no licence can still be held for verification — which is precisely why we ship the composition report with the goods rather than filing it internally.
Release is not the end of the story. Under China’s Customs Audit Regulations, customs retains post-release audit authority for three years. Several of the 2025–2026 penalty decisions involved shipments that had already left the country. “It got through” is not a defence.
Magnetized material is regulated separately. Beyond export control, magnets are dangerous goods for transport purposes under UN2807, with magnetic flux limits measured at 2.1 m and 4.6 m from the package. Over-limit consignments need shielding, and repacking requires re-testing — a magnet that passes the export control question can still be refused by an airline.
What to Ask Your Supplier Before You Order
Print this list. The answers determine both your price and your schedule.
| Question | Why it matters |
|---|---|
| Which rare earth elements are present in this grade, from your batch analysis? | Composition, not grade, determines control |
| Do you use grain boundary diffusion, and with which element? | The most common hidden source of Dy and Tb |
| Can you provide a third-party composition report stating method and detection limit? | The only defensible evidence of classification |
| Will the report be lot-specific, and will it ship with the goods? | Customs tests a sample; a report from a different batch will not match it |
| If the report shows Dy or Tb, what happens to my order and price? | You want this answered before you pay a deposit |
| What is your current licence lead time, and is it inside the quoted delivery date? | In our experience, about four months |
| Do you provide a magnetic flux test report for air freight? | UN2807 compliance is a separate gate from export control |
If the answers are vague — particularly on question two — treat the magnet as controlled until proven otherwise. The cost of being wrong in the other direction is not a delay; it is a penalty record.
Frequently Asked Questions
Do all neodymium magnets need a Chinese export licence? No. Only NdFeB magnets that contain dysprosium or terbium fall under the controlled catalogue codes (1C904 for terbium, 1C905 for dysprosium). Magnets made without either element are not controlled items.
Is it true that magnets at SH grade or below are never controlled? Not as a rule. In standard production, mid-range grades usually contain no heavy rare earths — but a producer using terbium-based grain boundary diffusion can put Tb into an SH magnet. Ask about the process, and confirm with a test.
What exactly is the 0.1% threshold, and is it official? It is a practical benchmark used in enforcement and laboratory screening. It is not a numeric threshold published in Announcement No. 18. Because the rule is underspecified, some practitioners take the stricter view that any detected Dy or Tb makes the magnet a controlled item.
Can my supplier simply write “not controlled” on the invoice? A statement without a lot-specific test report behind it carries very little weight. What customs and your own auditors need is a measurable result, from an accredited laboratory, with the method and detection limit stated.
How long does it take if a licence is required? In our experience through 2025 and 2026, about four months. That period sits inside the production schedule, so a controlled order should be placed five to six months before the magnets are needed.
We already shipped, and the test now shows dysprosium. What happens? Customs retains post-release audit authority for three years, and a number of published penalty decisions concern shipments that had already been exported. Settle the classification question before the goods move, not after.
Key Takeaways
- Composition decides, not grade. Control hinges on whether dysprosium or terbium is present in the finished magnet.
- Grain boundary diffusion is the hidden variable. The same nominal grade can be controlled or not depending on the producer’s process.
- 0.1% is an enforcement benchmark, not a published threshold — and there is no practical de minimis in the cases decided so far.
- The most common penalty cause is a careless declaration, not concealment. Declare specifically, and keep the element list complete.
- Licensing and inspection are separate controls. An HRE-free shipment can still be held, and release can be revisited for three years.
- If a licence is needed, plan on about four months — or design the heavy rare earths out. We explain which grades qualify in our guide to HRE-free NdFeB magnets.
Sources
- MOFCOM & GACC Announcement No. 18 of 2025 (export control on samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium items), effective 4 April 2025
- MOFCOM FAQ documents on the scope of rare earth export controls
- China customs enforcement decisions involving Dy/Tb classification of NdFeB shipments (2026), including Dy content of 0.15%, 0.18% and 0.372%
- Industry compilation of published export-control penalty decisions, 2025–2026 (at least 211 decisions published in 2025)
- Customs Audit Regulations of the PRC (post-release audit authority: three years)
- Trade press reporting on customs deployment of handheld XRF analysers for dual-use item screening at ports, 2026
- UN2807 / IATA rules on the transport of magnetized material (flux limits at 2.1 m and 4.6 m; shielding and re-testing after repacking)
Last updated: September 2026. Export control scope, enforcement practice and laboratory benchmarks are dynamic — verify the current position before making procurement decisions. This article is a practical procurement aid, not legal advice.
Need a straight answer on your own drawing? We manufacture sintered NdFeB magnets and SmCo magnets under a documented classification and testing process. Send us the drawing, the operating temperature and the annual quantity, and we will tell you in writing which category your part falls into — with the composition test behind it. Email info@hshardwares.com, phone or WhatsApp +86-13666656994, or request a quote.
You can also download our free Magnet Export Compliance Checklist (PDF) — a two-page classification and documentation aid for procurement teams.
Leave a Reply