MOFCOM Answers Common Identification Questions on Controlled Items Related to Tungsten and Tellurium

On February 28, the Bureau of Safety and Control of the Ministry of Commerce (MOFCOM), based on recent inquiries from enterprises and in communication with relevant departments of the General Administration of Customs, provided answers to common identification questions regarding tungsten, tellurium, and related items.

1. How can export operators determine whether the tungsten-related products they intend to export are subject to control as dual-use items?

Answer: Export operators should refer to the relevant provisions of the Announcement No. 10 of 2025 jointly issued by MOFCOM and the General Administration of Customs on the implementation of export control over tungsten, tellurium, bismuth, molybdenum, and indium-related items to determine whether the products intended for export are subject to control. If it is indeed difficult to make a determination, they can apply for export business consultation through the unified platform of the business system (https://ecomp.mofcom.gov.cn/loginCorp.html), specifying the technical indicators, main uses of the items intended for export, and the reasons for the inability to make a determination. MOFCOM will organize an assessment and provide a timely response.

2. Do the tungsten-related items under item 1C117.d of the aforementioned announcement include simple mixtures?

Answer: Simple mixtures of ammonium paratungstate, tungsten oxide, tungsten carbide with other items, and unsintered metallic tungsten carbide all fall within the scope of the dual-use items subject to control in this listing.

3. How should "mechanical processing" under item 1C117.c.2 of the aforementioned announcement be understood?

Answer: For the solid tungsten listed (1C117.c), it must simultaneously meet the material composition criteria (1C117.c.1) and the relevant size and shape requirements (1C117.c.2). Due to the material properties of solid tungsten, "mechanical processing" here refers exclusively to cutting processes such as turning, milling, planing, and grinding ("reducing from large to small"), and does not include processes such as extrusion, stretching, or tube expanding ("increasing from small to large").

4. Is ammonium metatungstate subject to control as a dual-use item?

Answer: Ammonium metatungstate is an acidic compound of tungsten and is not subject to control as a dual-use item in this listing.

5. Are sintered metallic tungsten carbide and related products subject to control as dual-use items?

Answer: Sintered metallic tungsten carbide, tungsten carbide plates (blocks, rods, balls), tungsten carbide cermets, tungsten carbide alloy powders, tungsten carbide scrap; cemented carbide drills, blades, etc. made from tungsten carbide; diamond composites; tungsten hooks (including tungsten steel), stamping dies (including tungsten steel), milling cutters (including tungsten steel); and tungsten wires are not subject to control as dual-use items in this listing.

6. Is tellurium-zinc-cadmium target material subject to control as a dual-use item?

Answer: Tellurium-zinc-cadmium target material is subject to control as a dual-use item in this listing.

7. Are solar modules made from cadmium telluride and zinc telluride subject to control as dual-use items?

Answer: Solar modules made from cadmium telluride and zinc telluride, cadmium telluride thin-film photovoltaic modules, cadmium telluride power-generating glass, and tellurium-zinc-cadmium high-resolution detectors are not subject to control as dual-use items in this listing.

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