Does China ban Germanium exports?
Following rising tensions between world great powers and US restriction on semiconductors products and equipment to China, China responded in kind with enforcing export controls of critical materials, including Germanium and Gallium.
Chinese restrictions on Germanium exports
China didn’t apply a total restriction on Germanium exports, but a licensing system for its exportation.
Official announcement from the MOFCOM
Beginning of July 2023, China Ministry of Commerce (MOFCOM) announced that Germanium and parts containing Germanium will be under export control (link in Chinese) from the first of August 2023.
Are optical components included in the Germanium export restrictions?
Due to its very good transmission in the 7-14µm spectrum, Germanium is widely used in optics for thermal vision systems with few alternatives.
As usual in China, announcements are not precise enough to determine specifical applications, a direct question from an optical part supplier to the MOFCOM got the vague answer that they have to consult online resources by themselves. The above official announcement that mention lots of related HS codes (custom categories short codes) does not include optical components like related to the codes 9001 & 9002.
This been said, in application China customs require that every part containing even a bit of Germanium (even in optical coatings) has to go through official declaration.
The short answer, from practical experience, is a big YES.
Which customers are given the green light for export?
As the final decision is at the courtesy of the government it is difficult to have a clear answer to this question. Here is a small chart on our understanding on this point :
| Situation | Likeliness of getting an export authorization |
|---|---|
| Final user is a company under sanctions from China | Null |
| Final user is a provider of US/NATO military | Close to null |
| Company or final customer is located in the US | Very difficult |
| Company does not want to disclose final usage or customer | Null |
| Non-military application, with transparency on usage and final customers names and location | High chances of success |
Impact on the Germanium price and availability
China provides more or less 2/3 of Germanium global supply, making it the biggest producer by far. The licensing system created a complexity and extended lead time which brought a surge in Germanium raw material price since 2023 and continuing, reaching close to 6000 USD/kg in September 2025.
Applying for an export license for Germanium optical components
As we have seen above, if a company wants to procure Germanium optical components, they need to go through the licensing process.
What does the export license looks like ?
Below is a picture of a license as delivered by the authorities :
It includes name of the exporter, validity of the license (6 months), customer and country where the parts will be exported to, weight, price and quantities of all the parts.
Each license is granted for one order, for a specific customer and usage and with fixed quantities and price, a new license has to be requested for each delivery / order.
Who can apply for an export license ?
Only companies with official registration in China and dealing with exports can apply for a license.
Process
The good news is that this process is completely free of charge for the applicant. The bad one is that it takes about 2 months if all the provided documents are ok.
Different steps for the application :
- Send an official Purchase order, including price, quantities and product description, the order should be addressed to the company that will take charge of the export license request.
- Fill-in the end user & end use certificate, you can download the template and fill-in the missing information. Add your company letterhead with company stamp and CEO (or equivalent) signature.
- The importer and end-user statement, confirms the Germanium parts will not be used for military application and neither resold to a third party. You can find a reference in the link. Add your company letterhead with company stamp and CEO (or equivalent) signature.
- The Original of the two documents above will need to be sent to the license applicant.
- Further information which need to be provided by email to the applicant :
- Company capital
- Date of establishment of the company
- Company registered address
- Company’s official business scope
- Total assets of company
- Phone number
- Number of employees
- Official website
- Last year’s sales revenue
- A first set of electronic documents will have to be validated by local customs of the license applicant in China
- After approval, all the files will be sent to central customs in Beijing for validation. It takes around 45 working days, more information may be requested during the process.
How SINOPTIX can help ?
SINOPTIX has a Chinese entity that can deal with the export license under our name, providing that customer give direct order to our Chinese structure and provide all the above-mentioned information, we can take in charge of the export license application.
