Does China bans Germanium export ?
Following rising tensions between world great powers and US restriction on semiconductors products and equipment to China, China respond in kind with enforcing export control of critical materials, including Germanium and Gallium.
China restrictions on Germanium exports
China didn’t apply a total restriction on the Germanium exports but a licencing system for it’s 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 it’s 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 specifics application, a direct question from an optical part supplier to the MOFCOM got the vague answers that they have to consult online resources by themselves. The above official announcement that mention lots of related HS code (custom categories short codes) does not include optical components ones like 9001 & 9002.
This been said, in application China customs require that every part containing a little bit of Germanium (even in the optical coating) goes through official declaration.
The short answer, from practical experience is a big YES.
Which customers can be granted a green light for the 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 :
| Stiuation | Likeliness of getting an export authorization |
|---|---|
| Final user is a company under sanction 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 Germanium price and availability
China provide 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 licence for Germanium optical components
As we have seen above if a company wants to procure Germanium optical component they need to go through the licencing request.
What does the export licence looks like ?
Below is a picture of a licence as delivered by the authorities :
It includes name of the exporter, validity of the licence (6 months), customer and country where the parts will be exported to, weight, price and quantities of all the parts.
Each licence is granted for one order, for a specific customer and usage and with fixed quantities and price, a new licence have to be requested for each delivery / order.
Who can apply to an export license ?
Only company with official registration in China and dealing with exports can apply for a licence.
Process
The good news is that this process is entirely free of charge, the bad one is that it takes time +/- 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 licence 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.
- Fill-in the importer and end-user statement, that confirms the Germanium parts will not be used for military application and neither resold to a third party. Add your company letterhead with company stamp and CEO (or equivalent) signature.
- Original of the two above documents will need to be posted to licence applicant.
- Further information 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 licence 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 licence 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 licence application.
