China’s New Graphite Restrictions

In recent years, export controls have moved to the forefront of foreign policy, and not only in the United States. The week of October 16, 2023, was marked by moves and countermoves that may have profound geopolitical implications. the Bureau of Industry and Security (BIS) released an updated tranche of rules aimed at complementing the October 7 semiconductor export controls, which significantly expands restrictions on artificial intelligence (AI) chips and semiconductor manufacturing equipment and adds 13 Chinese firms to the U.S. Entity List. With this expansion, the Biden administration took more sophisticated steps to limit China’s military advanced AI capabilities.

On October 20 and in response to the widened U.S. controls, China announced a new set of export restrictions on certain graphite products. As of December 1, Chinese exporters will be required to apply for permits to ship two types of the material, including “high-purity, high-hardness and high-intensity synthetic graphite material and natural flake graphite and its products.” The move comes two months after China restricted germanium and gallium products critical to semiconductor manufacturing, which came in the aftermath of another announcement by the Netherlands that it would support the United States’ chip controls with its own equipment curbs.

In both cases, China is leveraging its dominance of the global critical minerals and raw materials supply chain to respond to expanded economic security policies in the West. China produces 90 percent of the word’s gallium and 60 percent of germanium. Likewise, it is the world’s number one graphite producer and exporter and refines more than 90 percent of global graphite. However, while the August controls were aimed at the chips sector, China’s graphite controls have more bite in electric vehicle (EV) battery manufacturing since the material is used as a key input for anodes, the negatively charged portion of the EV battery.

The graphite controls are not specifically targeted at either bloc but are instead country-agnostic, meaning they could impact any of the country’s top customers, such as Japan, the United States, India, and South Korea. It could also be true that, similar to the gallium and germanium controls, China is initiating new licensing requirements but continues to facilitate most—if not all—exports under a presumption of approval. This would indicate Chinese use of controls as a geopolitical signaling device rather than a rote retaliation tool.

Supplying the Graphite Demand

Regardless, policies like the graphite controls crystallize the utility of the friendshoring agenda—moving supply chains to jurisdictions that do not pose serious geopolitical risks. In terms of U.S imports, China is also not the only source, although, at 33 percent of imports, does account for the largest single source of imports. Mexico (21 percent) and Canada (17 percent), as well as India (9 percent) are other large exporters of graphite to the United States. Other U.S. allies are in more challenging situations when it comes to dependence on Chinese EV inputs, however. About 93 percent of Korea’s anode materials, and 90 percent of Japan’s graphite, comes from China.

While China is the current top graphite producer, it is not the only option for obtaining a sufficient supply. According to the United States Geological Survey, Turkey (27.3 percent) and Brazil (22.4 percent) account for half of the world’s natural graphite resources. China is third, with 16 percent, followed by Madagascar (7.9 percent), Mozambique (7.6 percent), Tanzania (5.5 percent), and Russia (4 percent). The inevitability of having to secure non-Chinese graphite supplies also highlights the utility of traditional trade policy, which can anchor existing and new international partnerships through the conclusion of concrete deals.

Automakers are accelerating production to satisfy a large uptick in orders, although carmakers recall the supply chain contractions due to the pandemic, battery materials importers have learned the risks of overreliance on one country. In order to stay ahead, large automotive industry players have been investing in mining projects to ensure a more steady supply of battery inputs. However, getting these mines ready for operations takes between 5 to 10 years, and these projects are still largely in preproduction.

This latest episode is yet another impetus for governments and the private sector to diversify away—or “de-risk”—from dependencies on China. According to the International Energy Agency, global sales of EVs are soaring. Sales exceeded 10 million units last year, growing 55 percent from 2021.Sales are slated to grow even further, potentially reaching 14 million vehicles this year. The market for graphite used in batteries has also rise exponentially, growing by 250 percent in the past five years as carmakers try to lock in enough supplies of critical inputs to satisfy demand.

China’s new controls are set to incentivize Canada and Mexico to continue ramping up their own domestic capacity to satisfy U.S. demand as the Inflation Reduction Act’s incentives continue to attract EV producers. Governments of countries particularly dependent on Chinese exports are already racing to find alternative sources of supply. South Korea’s trade minister Ahn Duk-geun asserted that his country “is prepared to look for alternative sources of graphite if China’s newly strengthened export controls on the key material used in electric-vehicle batteries cause a severe shortage.” He also pointed to the U.S.-led Indo-Pacific Economic Framework for Prosperity (IPEF): “One difference is the 14 IPEF countries now established the supply chain agreement and the mechanism to protect us,” he said. “As soon as we have a problem, within two weeks we need to share the information and we will coordinate our response mechanism.”


China’s control policies come during increased pressure from the United States and its allies to move supply chains out of China, while enhancing mutual trade and defense tools. The European Union has launched an investigation into whether to levy tariffs on Chinese-made EVs, and the United States is likely to follow with a Section 301 investigation. The European Union and United States are also engaged in ongoing negotiations to conclude a deal on critical minerals, which came up during a recent leaders’ summit in Washington, D.C., and are likely to pursue concurrent trade defense measures to safeguard against overcapacity of steel.

The nature of recent controls has demonstrated how economic security can sometimes invite significant costs. For now, the U.S. government has made a determination that the costs of controls are outweighed by the benefits. A major risk in this economic security escalation is that China’s controls on raw materials seriously disrupt the ability to produce critical, emerging, and green technologies. Furthermore, these weapons can easily produce greater economic and geopolitical bycatch as the net expands, potentially touching a host of other critical inputs for U.S. and allied supply chains.

Emily Benson directs the Project on Trade and Technology and is a senior fellow with the Scholl Chair in International Business at the Center for Strategic and International Studies (CSIS) in Washington, D.C. Thibault Denamiel is a research associate with the Scholl Chair in International Business at CSIS.

Emily Benson
Director, Project on Trade and Technology and Senior Fellow, Scholl Chair in International Business