According to graphite industry publication Graphite Alliance (石墨盟), an export declaration filed in Xiamen has resulted in a fine, after the graphite it described was found to be a controlled item that could not be shipped without a licence.

On 9 May 2026, the company instructed a customs broker to declare a consignment of “graphite crucibles”, moving the goods through a bonded port zone and clearing them across the second line, the boundary between the zone and the domestic market. On 15 May, the same goods were declared for export as intra-zone logistics cargo, with Germany as the destination. At the first line, the boundary between the zone and overseas, customs inspected the shipment and sent samples for testing.

Testing identified the crucibles as a controlled dual-use item under 1C108, “graphite and its products”, in category B of China’s Dual-Use Items Export Control List, the classification covering high-performance artificial graphite.

Having moved a controlled item abroad without authorisation, the exporter was found in breach of the Export Control Law and the Customs Law, and was fined under the Export Control Law and the Administrative Penalty Law.

What Counts as Controlled

Controlled graphite sits under a single entry, 1C108, split into categories A, B and C. Whether a product is caught comes down to a two-stage test: identity first, then specification. Natural flake graphite is controlled on identity alone; artificial graphite only once it meets set performance thresholds.

On the natural side, it is flake graphite and its products, category C, that are controlled, including finished forms such as spheroidised and expanded graphite. Blending flake into a powdered “earthy” grade to disguise it makes no difference: where testing finds the controlled material, the shipment is treated as controlled.

On the artificial side, a grade is caught only if it meets every threshold in its category. Category A requires a density above 1.72 g/cm³, a tensile fracture strain of 0.7% or more, and a coefficient of thermal expansion no greater than 2.75 × 10⁻⁶/°C at 20°C. Category B, where the crucibles fell, requires purity above 99.9%, flexural strength above 30 MPa, and density above 1.73 g/cm³.

Those limits leave a good deal outside the scope. The Ministry of Commerce’s guidance confirms that artificial graphite powder is not controlled, nor are metal- or fibre-reinforced products such as packing, gaskets, composite sheets, wire and rings.

Why These Grades Are Controlled

High-specification graphite is closely tied to several strategically sensitive industries, and the stated basis for control is national security, preventing sensitive material from reaching particular end users or uses. The three categories map onto distinct applications.

Category A, fine-grained isostatic graphite, retains its dimensions and properties at high temperature. It is used in the furnaces that grow single-crystal silicon for semiconductors and solar, in the moderators and reflectors of nuclear reactors, and in electrodes for electrical discharge machining.

Category B, the high-purity, high-strength, high-density grade the crucibles were found to be, is used in nuclear reactors, in the high-temperature stages of semiconductor manufacturing and in heat-resistant aerospace structures.

Category C, natural flake graphite and its products, is the grade the new-energy sector depends on. Spheroidised graphite made from flake is the core anode feedstock in lithium-ion cells, and therefore central to the EV supply chain, while expanded graphite is used in sealing and fire-resistant applications.

In each case the material either underpins a strategic industry or can be adapted to military heat-resistant and sealing components, and it is that dual character that places it on the control list.