On July 3, China’s Ministry of Commerce announced a new series of restrictions on gallium and germanium exports, two vital elements used in semiconductor and consumer electronics manufacturing.
China’s new restrictions have left many exporters wondering how far-reaching the new rules extend. According to Covington, an American multinational law firm, “the announcement of the export restrictions details the specific customs classifications codes” of commodities affected by the new rules. “Notably, the new rules apply only to these specific commodities and not to finished products that incorporate them.”
While China’s new gallium and germanium restrictions may come as a surprise to some, they mark a continuation of national security tensions between China and the United States.
In an article for Foreign Investment Watch by Nathanial Reid, an attorney and China analyst, found that “evidence from CFIUS cases…supports the idea that wide bandgap semiconductors are a key point of emphasis” for the U.S. government with regards to national security.
“Wide bandgap” semiconductors are those that allow “power electronic components to be ‘smaller, faster, more reliable, and more efficient than their Silicon (Si)-based counterparts.’”
CFIUS, or the Committee on Foreign Investment in the United States, is an interagency committee “authorized to review certain transactions involving foreign investment in the United States…in order to determine the effect of such transactions on the national security of the United States.”
While transactions reviewed by CFIUS that involve gallium are few and far between, those presented are rarely approved. Here is a brief overview of the known cases around gallium:
In the week since China announced its new restrictions, the market for gallium and germanium has seen a price shift, with gallium rising $43 to $326 per kilogram. Germanium’s pricing has seen a milder shift of less than 2%.
While political and news sources speculate on how this move impacts the growing trade tensions between China and the West, manufacturing companies are looking towards industry giants for measurable impact.
Over the week, more companies announced internal reviews to assess the impact of China’s trade restrictions, including Intel, Microchip, and Infineon.
Microchip said its initial assessment found no material impact, while Intel said it was still assessing the impact. A spokesperson for the company noted that “our strategy of having a diverse, global supply chain minimizes our risk to local changes and interruptions.”
Infineon said it relies mainly on sources outside of China for its supplies and did not foresee any real impact.
Additionally, mining companies in Congo and Russia are looking to boost production on gallium and germanium in an attempt to tempt new buyers away from China.
On July 3, China’s Ministry of Commerce announced a new series of restrictions on gallium and germanium exports, two vital elements used in semiconductor and consumer electronics manufacturing.
Beijing officials announced starting August 1, 2023, exporters will need a license to ship gallium and germanium out of the country. The application process will require exporters to identify importers, end users, as well as how the metals will be used.
While China’s official announcement cites national security and state interests as the driving motivator, the act comes amidst a growing technology trade war between China and the United States and Europe.
Neither element is found naturally; both are byproducts from the harvesting of other metals such as zinc and bauxite.
Both metals are listed as technology-critical elements (TCE) that play a vital role in the development and manufacture of emerging technologies. The European Commission features both elements on its Critical Raw Materials (CRM) list, and the U.S. Department of Energy cites them in a 2021 report as “essential to the economic prosperity and national defense of the United States.”
According to the U.S. Department of Energy, the United States relies on China for 95% of its gallium supply. The report found that the United States “does not have sufficient domestic resources to meet expected demands for certain critical materials, such as cobalt and gallium.”
China is also the main producer of germanium, “making up 80% of the element’s total worldwide production during 2012-2016.”
And the demand for both is only growing.
Studies show that gallium production has increased “at a rate of 7% per year on average over the past decades, much faster than most industrial metals.” This demand is exacerbated by the demand for clean energy technology both from consumers and countries aiming to meet their energy goals as stated in the Paris Agreement.
Germanium is also seeing increasing demand in light of historically upward growth and the growing need for solar cells and 5G networks.
Demand, combined with a tightening grip on access due to these new restrictions, may bring a new test for electronic supply chain management teams.
Japan and South Korea are the largest importers of gallium and germanium from China.
In response to the news, South Korea’s ministry conducted a meeting to assess the situation reported an article from the Financial Times. “The latest sanctions are expected to have limited impact on sourcing in the short term,” remarked the deputy minister for South Korea’s Office of Industrial Policy. “But we cannot rule out the possibility of the sanctions lasting longer and expanding to other items.” The official said they would be closely assessing the situation for any new changes.
Japanese trade minister Yasutoshi Nishimura said Japan’s government was looking at the impact the new regulations might have.
Reuters reported a spokesperson from the U.S. Department of Commerce said the United States “firmly” opposed the act and would be working with allies to tackle the issue. No official actions have been taken to directly challenge or address the new restrictions.
According to the South China Morning Post, a Hong-Kong based newspaper owned by Alibaba, Chinese companies may be the most heavily impacted by the new licensing system. China may be the largest producer of gallium and germanium in the world, but it’s not the only source for low-purity gallium production. Other producers include Japan, the Republic of Korea, and Russia.
Companies seeking to get around China’s new restrictions may be able to find business elsewhere if need be, leaving Chinese companies in the lurch.
While governments and businesses scramble to assess the fallout, some industry experts are chalking the new restrictions up to a lot of noise. An article released by DigiTimes, a newspaper for the semiconductor, electronics, and communications industries in Taiwan, pointed to three key reasons why manufacturers might not see any initial fallout from these new restrictions:
Top worldwide producers of gallium include Japan, the Republic of Korea, Russia, and Ukraine. Germany and Kazakhstan were previously producers but ceased primary production in the 2010s. Germany’s production stopped in response to the high operating costs and cheapness of the gallium produced by China.
After China, the United Kingdon, Russia, and the United States are the primary suppliers of germanium, with some additional production in Finland.
Key semiconductor manufacturers and designers are also addressing the news, including industry giants such as Taiwan Semiconductor Manufacturing Company Ltd. (TSMC) and NXP Semiconductors N.V.
Wolfgang Niedermark, an Executive Board Member of BDI, a leading organization of German industry, saw the news as further evidence for reducing their raw materials dependency abroad. He called the restrictions an illustration of “the urgency for Europe and Germany to quickly reduce their dependence on raw materials now,” a stance that mirrors his long-held policy on reducing Germany’s economic dependency on China.
A further analysis leveraging Z2Data’s data intelligence platform found additional commodities and suppliers that may be affected by these new restrictions:
To learn more about how Z2Data delivers in-depth analysis on the impact of new trade compliance requirements, schedule a product demo.[MA1]
While new restrictions add complexity to the supply chain process, their actual effect remains to be seen. China’s new restrictions don’t prevent exporters from obtaining either element—they put a license on the process. And until applications are submitted it’s too soon to say if there will be restrictions or rejections around that process.
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