US Extended Its Export Rule Pause; China Has Not Renewed Its Rare Earth One

The US-China trade truce rests on two written legs, and two days before November 10 they stand in different places. The Commerce Department's Bureau of Industry and Security (BIS) published a rule on November 5 extending its own pause to January 10, 2027.

China has published no notice extending the pause on the rare earth controls it announced in October 2025. The text that created the pause explicitly suspends those rules only until November 10, 2026.

The Truce Rests on Two Separate Documents

On October 9, 2025, China announced a control package made up of six notices. It covered rare earth processing equipment, related technology, several heavy rare earths and lithium battery materials.

After the late-October Trump-Xi meeting, Beijing suspended the whole package for a year on November 7, 2025. The US suspended its Affiliates Rule on November 10, 2025. That rule extends blacklist restrictions to any affiliate that a listed company owns 50% or more of.

According to Caixin, the rule swept in roughly 20,000 Chinese entities. Baker McKenzie says the new BIS text is due in the Federal Register on November 9; the rule has not been withdrawn, only kept suspended.

What Beijing Said, and What It Did Not Write

Treasury Secretary Scott Bessent announced on September 23 that the truce had been extended to January 10, 2027. China's Commerce Ministry confirmed on September 28 that the trade arrangements were extended to the same date.

That statement mentioned neither rare earths nor which notice had changed. In China, the pause was created by a numbered notice, and no new notice has amended it. Legal and industry notes published between November 3 and November 8 reach the same conclusion.

If the pause lapses, the 0.1% rule and the equipment and technology controls return from the first minute of November 11, Beijing time. The April 2025 licensing requirement on seven elements was never suspended at all.

The market read the truce as a single agreement. Legally, there are two documents, and only one has been renewed.

How the 0.1% Threshold Works

According to Pillsbury, this is China's first extraterritorial rule, modeled on the US de minimis rule. Even if a product is made outside China, its sale needs Beijing's approval when Chinese-origin rare earth content crosses the threshold.

Magnets are a small slice of most product prices, but the threshold is so low that being small offers no protection. The rule's power comes not from high ratios but from a low threshold that catches almost every product.

The cost of a licensing regime shows up in prices. Reports put high-purity gallium above $1,800 per kilogram in the West in October versus $245 in China, a gap of more than seven times. Gallium has required a Chinese license since 2023.

A Year on the Calendar

The common expectation in the industry is that Beijing will publish a notice at the last minute. One Substack writer who tracks the issue summed it up: "Everyone expects a notice. Nobody has seen one."

Prices also treat the risk as small. MP Materials rose 4.95% to $35.41 on November 6, and USA Rare Earth gained 10.85% to $8.23. Sources do not tie the move directly to the November 10 date, and MP is still below half of its $76.80 high.

The broader market that week was driven by data center politics and interest rates. The chart below shows the Nasdaq 100 fund over the past month, counted back from today.

What It Means for Investors

• The market is pricing a fully extended truce; it is not pricing that China's side of the extension is not yet in writing.
• If the pause lapses, manufacturers whose products contain Chinese-origin magnets are most exposed; Seagate and Western Digital were named in 2025 magnet warnings.
• The moment to watch is 00:00 Beijing time on November 11, or 11:00 a.m. ET on November 10; October CPI comes out the same morning at 8:30 a.m. ET.
• The risk to this view is a last-minute numbered notice from China, which would close the gap and push supply chain risk back to January 10.

Sources: The date and scope of the BIS extension rely on notes from Baker McKenzie, Thompson Hine and Reed Smith dated November 5-6. China's suspension text and scope come from Pillsbury's November 2025 note. The count of firms covered by the Affiliates Rule is from Caixin. The finding that China has issued no new notice relies on industry publications dated November 3-8. Gallium prices come from reports citing Rare Earth Exchanges, and share prices are November 6 closes.