Resolution criteria

• Resolves YES if, by 23:59 Beijing time on March 31, 2026, China issues and puts into effect an official measure that explicitly prohibits exports of tungsten products to the United States or U.S. persons/entities (i.e., a U.S.-specific ban or suspension such that “exports … to the United States shall not be permitted”). Acceptable sources for verification are an announcement/notice on: the Ministry of Commerce (MOFCOM) site, the General Administration of Customs (GACC), or the State Council; reputable wire reports quoting the official directive are acceptable if the primary page is temporarily inaccessible. Examples of tungsten products include APT (HS 2841801000), tungsten oxide (HS 2825901200/2825901910/2825901920), tungsten carbide (HS 2849902000), and solid tungsten/≥80% W alloys (HS 8101940001/8101991001/8101999001). Sources: MOFCOM Feb 4, 2025 Q&A on tungsten controls; translation of Announcement No. 10 (2025) listing covered tungsten items and HS codes; Reuters precedent for U.S.-specific mineral bans. (mofcom.gov.cn)

• Resolves NO if no such U.S.-specific prohibition is in effect by the deadline.

• Exclusions: generic licensing/permit regimes without an explicit U.S.-specific prohibition; global (all-destination) bans; informal non-issuance of licenses; firm-specific bans that do not cover tungsten products as a class.

Background

• On Feb 4, 2025, MOFCOM and GACC imposed export controls (licensing) on tungsten-related items such as APT, tungsten oxides, and tungsten carbides—these were not outright bans. (mofcom.gov.cn)

• The covered tungsten products and indicative HS codes are detailed in Announcement No. 10 (2025). (chemradar.com)

• China has previously used U.S.-destination–specific bans for other minerals (e.g., gallium, germanium, antimony) per MOFCOM directives reported by Reuters. (reuters.com)

Considerations

• “U.S.-specific” requires the United States (or U.S. persons/entities) to be named as the prohibited destination/counterparty in the text of the measure; mere delays or zero licenses do not qualify.

• Verification: check MOFCOM announcement pages and the export control portal for new notices; if inaccessible, contemporaneous Reuters/AP wires quoting the official wording may be used for resolution. (mofcom.gov.cn)