Customs authorities at Shanghai Pudong International Airport have fined ULVAC Materials (Suzhou) Co., Ltd. for exporting a graphite item to Japan without the export licence required under China’s dual-use controls, according to an administrative penalty decision issued by the airport customs office.

The decision imposed a fine of RMB 10,000 (~US$1,400) and was dated 9 June 2026. ULVAC Materials (Suzhou) is a wholly-owned Chinese subsidiary of Japan’s ULVAC, Inc., a vacuum-technology and materials group listed in Tokyo.

The Penalty

According to the customs decision, on 8 January 2026 the company engaged a courier service to declare a shipment to Japan under a duty-free category, listing the goods as one “carbon plate (used)” under commodity code 6815190090, with a declared value of FOB RMB 3,500 (~US$490).

Customs inspection found that the item was in fact graphite. The authority recorded its measured properties as a purity of 99.99%, a density of 1.91 g/cm³ and a flexural strength of 58 MPa, placing it within the scope of export controls on synthetic graphite materials and products.

Those figures sit above all three of the thresholds China set in 2023 for controlled synthetic graphite, which capture material that is simultaneously high-purity (above 99.9%), high-strength (flexural strength above 30 MPa) and high-density (above 1.73 g/cm³).

The Finding

The customs office said that exporting controlled items of this type requires a Dual-Use Items and Technologies Export Licence to be declared and presented to customs, and that the company failed to provide one at the time of declaration.

The authority found that this breached provisions of China’s Customs Law and Export Control Law on truthful declaration and presentation of documents, and constituted a violation. It put the value of the controlled goods involved at RMB 3,500 (~US$490).

The penalty was issued under the Export Control Law and the related customs procedural rules. Under that statute, exporters that ship controlled items without a licence face confiscation of unlawful gains and graduated fines, with the lighter end of the scale applying where there is no, or limited, unlawful business turnover.

A widening enforcement picture

The penalty is the second China graphite export-control enforcement action GraphiteHub has reported in recent months. In April, listed refractories producer Punai Group disclosed a criminal indictment over the alleged smuggling of more than 1,200 tonnes of natural flake graphite to its overseas subsidiaries through misdeclared HS codes.

Taken together, the two cases span both ends of the enforcement spectrum: a modest administrative fine over a single mislabelled item, and a criminal prosecution involving corporate and individual defendants. They point to sustained scrutiny of how graphite is classified and declared at the Chinese border.

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Punai Group Indicted for Smuggling 1,243 Tonnes of Natural Flake Graphite to US Subsidiary

Background

ULVAC Materials (Suzhou) was established in 2009 in the Suzhou Industrial Park, Jiangsu Province, as a wholly-owned subsidiary of ULVAC, Inc. It describes its core business as supplying high-purity sputtering targets and vacuum deposition materials for the flat-panel display, OLED and semiconductor industries.

Parent company ULVAC, Inc., founded in 1952 and headquartered in Chigasaki, Japan, trades on the Tokyo Stock Exchange under the code 6728 and specialises in vacuum equipment, materials and related products for the electronics, semiconductor and industrial sectors.