China's suspended rare earth rule runs out on November 10: what do I ask a motor supplier for?

Le Thu Ha vnExport Compliance Officer · An electronics contract manufacturer, northern Vietnam

We mount motors, speakers and small sensors. We do not make the magnets inside them, and nothing on my bill of materials tells me what a magnet is made of or what that material is worth.

That is the problem sitting on my desk. One of the announcements China published last October reached past its own border: a product made outside China would need a Chinese export licence if the controlled rare earth material of Chinese origin inside it came to 0.1 percent or more of the finished product's value. A month later that whole package was suspended, and the suspension runs to November 10. Whether it is extended after that, I do not know, and I will not guess here.

I am openly unsure whether a Chinese licensing rule can bind a Vietnamese exporter at all. I have not read the legal basis and I am not going to pretend otherwise. The floor side I am sure about. To answer a value test like that I would have to ask every supplier of a finished component for the value of the rare earth inside it, and I have never asked anyone for that figure. Origin declarations I can collect. This one sits further up the chain than my supplier usually looks.

Has anyone put that question to component suppliers yet, and what form did you send them?

Asked 23 Sept 2026

3 replies

Aya Morimotojp2w ago

I may have misunderstood, since I sit on the other end of your question. Requests like this arrive on my desk in Osaka and I am the one who signs the answer.

What I can sign is presence and origin: whether a controlled element is in the magnet, and where that material was processed, as far as my own supplier told me. What I cannot sign is a value share. My purchase price for a finished magnet is not the value of the material inside it, and my supplier will not open their cost sheet to me any more than I would open mine to you.

So ask those two things separately, and date the statement. Ours carries a validity line and a promise to reissue on change. If the rule switches back on I would rather send you a version two than a correction.

Doug Vasquezus2w ago

Reading this from the buying end, and I would take your answer over most of what reaches me. The trouble is that the desks I write to do not answer like yours.

What comes back to me is a datasheet with a grade name on it and a line saying the material conforms to that grade. Ask twice and a sales manager sends a letter saying the product complies with all applicable export regulations. That is a sentence, not a figure, and it is not presence and origin either.

The other half of what you said lands on me. If nobody signs the value share, the blank travels. My own customers have started sending me content declarations, and the value column is sitting on those. I sign what I can prove and leave the rest empty, and I would rather be argued with than invent a share of a price I never saw.

So the thing I am stuck on. When a supplier sends nothing but a grade name, do you drop them, or do you pay to have the part tested.

Le Thu Havn2w agoAuthor

Then I will stop asking for the figure. Both of you have told me the same thing from opposite ends of the chain.

What goes in my origin file is two lines instead of one: presence and origin from the supplier, dated, with the reissue promise Aya described, and the value column left empty. Beside that blank I will keep the date I asked, who I asked, and the sentence that came back. An auditor can then argue with my supplier rather than with me.

Doug, on testing: a laboratory returns composition by weight. It does not return a share of a price. Paying for the test strengthens the presence line and leaves your value column as empty.

Whether an empty column satisfies anyone enforcing that rule, I do not know.

3 replies

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