【Domestic News】China Imposes Export Controls on Dual-Use Items to Japan, Covering Gallium Oxide, Diamond, and Third- and Fourth-Generation Semiconductor Materials and Technologies

      It has been reported that on January 6, the Ministry of Commerce announced that, in accordance with the Export Control Law of the People’s Republic of China and other relevant laws and regulations, and in order to safeguard national security and interests as well as to fulfill international non-proliferation obligations, a decision has been made to strengthen export controls on dual-use items to Japan.

      The current export controls cover multiple high-end materials, technologies, and specialized equipment with significant dual-use characteristics, playing a key role in missile guidance, high-power laser weapons, radar, electronic warfare, and power electronics.

      Diamond Window Materials possess extremely high hardness, thermal conductivity, and broadband optical transmittance (particularly in the infrared spectrum). They can be used in high-power laser systems, missile infrared seeker windows, space optical equipment, and precision optical sensors, and are capable of withstanding extreme thermal loads and mechanical impacts, making them indispensable core components of advanced weapon systems.

      The controls also include technologies for producing Six-Axis Press Equipment and process technologies for synthesizing Synthetic Diamond Single Crystals or Cubic Boron Nitride (c-BN) Single Crystals using a Six-Axis Press. The Six-Axis Press is a China-developed, widely industrialized ultra-high-pressure device and represents the key global production method for Synthetic Diamond and c-BN Single Crystals. These technologies directly support the use of high-end diamond in military heat sinks, optical windows, and cutting tools, carrying significant strategic value.

      In addition, the control list involves high-power Microwave Plasma Chemical Vapor Deposition (MPCVD) Equipment (microwave power > 10 kW, frequency 915 or 2450 MHz). This type of equipment is currently the most advanced method for growing large-size, high-quality optical-grade Diamond Single Crystals and polycrystalline films, and is directly used in the production of military diamond infrared windows and high-power laser windows.

      The control list also includes Silicon Carbide, Gallium Nitride (GaN), and Gallium Oxide (Ga₂O₃). The applications of Silicon Carbide, Gallium Nitride, and Gallium Oxide in the semiconductor field are expanding rapidly, particularly in power electronics, high-frequency electronics, and high-efficiency energy conversion devices. Gallium Nitride (GaN) is a core third-generation semiconductor material widely used in high-frequency, high-power RF devices and radar; Gallium Oxide (Ga₂O₃), with a wider bandgap, has great potential in ultra-high-voltage power electronics and deep-ultraviolet detection. These materials not only significantly enhance system performance but also effectively reduce energy losses, making them critical for technological innovation in green energy, aerospace, and communications.

      Meanwhile, according to China Daily and reliable sources, the Chinese government is reportedly considering tightening the export licensing review for medium- and heavy-rare-earth items listed on April 4, 2025, including Samarium, Gadolinium, Terbium, Dysprosium, Lutetium, Scandium, and Yttrium.

      An assessment by Nomura Research Institute shows that Japan’s supply of heavy rare earths, such as Dysprosium and Terbium, used in Nd magnets for electric vehicle drive motors, is almost 100% dependent on China. Should exports be restricted, Japan’s economy would face significant impacts. If Chinese restrictions on rare earth exports to Japan last three months, the estimated loss would be around ¥660 billion, reducing annual nominal and real GDP by 0.11%. If the restriction continues for one year, the loss could reach approximately ¥2.6 trillion, decreasing annual nominal and real GDP by 0.43%.

      According to the Regulations of the People’s Republic of China on Export Control of Dual-Use Items and Technologies, dual-use items refer to goods, technologies, and services that have both civilian and military applications or can enhance military potential, especially those that can be used in the design, development, production, or use of weapons of mass destruction and their delivery systems, including related technical data.

      The Catalogue for the Administration of Import and Export of Dual-Use Items and Technologies specifies the export control list, including specialized materials and equipment, chemical products, microorganisms and toxins, material processing, electronics, computers, telecommunications and information security, sensors and lasers, navigation and avionics, ships, aerospace and propulsion, and other categories.

Selected items include:

2B Testing, Inspection, and Production Equipment
      394 Microwave Plasma Chemical Vapor Deposition (MPCVD) Equipment specifically designed or manufactured with:
      a. Microwave power greater than 10 kW;
      b. Microwave frequency of 915 or 2450 MHz.

2C Materials
      620 Diamond Window Materials:
      a. Curved Diamond Window Materials;

621 Diamond Window Materials:
      b. Planar Diamond Window Materials with all of the following characteristics:

      1.Diameter ≥ 3 inches, single crystal or polycrystalline;

      2.Visible light transmittance ≥ 65%.

2E Technologies
      629–630 Technologies for:
      a. Producing Six-Axis Press Equipment;
      b. Synthesizing Synthetic Diamond Single Crystals or Cubic Boron Nitride Single Crystals using a Six-Axis Press.

3C Materials
      659 Gallium Metal Items:
      a. Gallium Metal (Elemental)

      660 Gallium Nitride (including but not limited to wafers, powders, scraps, etc.)

      661 Gallium Oxide (including but not limited to polycrystals, single crystals, wafers, epitaxial wafers, powders, scraps, etc.)