1C117.c: The Missile Clause the February Announcement Dropped

Two Chinese texts describe entry 1C117.c, and they do not say the same thing. The consolidated list, in force since 1 December 2024, puts a missile-use condition inside that entry. The announcement of 4 February 2025 restates the entry without that phrase, and adds a sentence saying the list was updated in step.

What the list says

The entry is 1C117.c of the consolidated dual-use list that took effect on 1 December 2024. Its heading reads, in the published Chinese: 具有以下所有特性，用于制造导弹部件的固态钨. Translating the operative words rather than the whole line: solid tungsten, for use in the manufacture of missile components, having all of the following characteristics.

The characteristics are a composition test and a geometry test, and both must be met.

1. Solid tungsten, excluding particles and powder, meeting any one of three composition groups: tungsten, and tungsten alloys of at least 97% tungsten by weight, neither of them already controlled under entries 1C226 or 1C241; tungsten-copper alloys of at least 80% tungsten; tungsten-silver alloys of at least 80% tungsten with at least 2% silver.
2. Material that can be machined into a cylinder of at least 120 mm diameter and 50 mm length, a tube of at least 65 mm bore, 25 mm wall and 50 mm length, or a block of at least 120 by 120 by 50 mm.

The exclusions in group 1 sit in one phrase in the source, 非1C226、1C241项下管制的钨及钨含量大于等于97%（按重量）的钨合金, which can be read as governing elemental tungsten alone or the whole coordination. It is read here as governing both.

The entries themselves are not on the announcement page (Announcement No. 51 of 2024); they are in Annex 1, a 141-page PDF attached to it.

What changed in February

Announcement No. 10 of 2025, issued on 4 February, restates 1C117.c in section 一, under the heading 钨相关物项. Inside 1C117.c itself, the substance changes in one place; the other edits are wording and customs codes. The announcement does more than that line of the entry, though: it also moves the technology entries, as the last section below sets out.

The five codes are 8101940001, 8101991001 and 8101999001 on the first two composition groups, and 7106919001 and 7106929001 on the silver group. The only other wording change is 以下 becoming 下述, twice: once in the heading and once in sub-item 1.

The molybdenum entry kept its clause

Section 四 of the same announcement covers 1C117.b, the molybdenum entry, and its text reads: 1C117.b．钼粉：用于制造导弹部件的钼含量（按重量）大于等于 97%、颗粒尺寸小于等于 50×10-6m（50μm）的钼及合金颗粒(参考海关商品编号：8102100001). In English: molybdenum powder, that is molybdenum and alloy particles, for use in the manufacture of missile components, with a molybdenum content of at least 97% by weight and a particle size of 50 µm or less.

In the list the two entries sit next to each other, molybdenum at 1C117.b and tungsten at 1C117.c. The announcement puts them in different sections, 四 and 一, and keeps the purpose clause on one while removing it from the other.

A drafter who does that has made a choice. The alternative explanation, that the omission is sloppy drafting, cannot be ruled out from the two texts alone, but it is the less likely reading: both tests and every threshold in them survive unchanged, and on this entry the other edits are a synonym used twice and five added customs codes.

What the announcement says about the list

Announcement No. 10 closes with two sentences, and the second is the one that matters: 本公告自发布之日起正式实施。《中华人民共和国两用物项出口管制清单》同步予以更新. The announcement takes effect on publication, and the consolidated list is updated in step.

So if the list was conformed in step, the entry as it now stands should read as this announcement reads, without the purpose clause. That is the reason the clause is treated here as withdrawn.

What the sentence does not do is print the amended entry. The announcement carries no attachment and no revised list text, and the edition of the list this page can read is the one published in November 2024. A compliance file can cite the announcement and its date; it cannot quote the amended entry as the list now carries it, unless the file’s author holds a later edition.

What this means for a buyer

The announcement keeps two tests. A billet that falls into one of the three composition groups and can be machined into a cylindrical bar of at least 120 mm diameter and 50 mm length meets them. What the 2024 entry adds, and the announcement does not, is the purpose the material is bought for.

The carve-out is narrow, and it is easy to misread. There are two entries in it, not one.

1C226 covers tungsten, tungsten carbide and alloys containing 90% or more tungsten, but only where two further conditions are met: a hollow, symmetrical cylindrical body, including cylindrical sector segments, with a bore of 100 to 300 mm, and a weight above 20 kg. Tungsten products specially designed for counterweights or gamma-ray collimators are excluded.

1C241 covers rhenium, alloys containing 90% or more rhenium, and alloys where rhenium and tungsten together reach 90%, under the same two conditions: the same hollow cylindrical shape with a 100 to 300 mm bore, and the same 20 kg weight.

A solid billet fails the shape condition, and a heavy one can satisfy the weight condition, so neither entry reaches bar stock. What they reach is a hollow symmetrical body, or a sector segment of one, with a bore between 100 and 300 mm and a weight above 20 kg. There is no wall-thickness condition, so a long thin-walled section of the right bore and weight is caught too.

What this means for a supplier

A supplier working from the 2024 list applies a purpose test that the announcement does not carry, and treats the customer’s stated end use as the thing that decides. On the announcement’s text it is not: composition and machinability decide, and a billet bound for a die shop falls inside the entry on the same terms as one bound for a missile programme.

The other tungsten entries

The other tungsten entries in the announcement are 1C117.d for ammonium paratungstate, tungsten oxide and tungsten carbide, where the carbide is the grade not already under 1C226; 1C004 for tungsten-nickel-iron and tungsten-nickel-copper alloys, which carries four conditions, a density above 17.5 g/cm3, an elastic limit above 800 MPa, an ultimate tensile strength above 1270 MPa and an elongation above 8%; and 1E004 with 1E101.b for the technology and data used to make 1C004, 1C117.c and 1C117.d.

That last pair is where the change is easiest to miss. In the 2024 list, 1E004 reached 1C004 alone, and 1E101.b reached 1C117.b, 1C117.c and 1C117.d. The announcement names both codes together against 1C004, 1C117.c and 1C117.d in section 一, and then restates 1E101.b on its own against 1C117.b in section 四. Read as a joint designation, that leaves both codes reaching more than they did: 1E004 gains 1C117.c and 1C117.d, and 1E101.b gains 1C004. The pair’s combined scope is the same as before, but the technology control now attaches to 1C117.c through a code that did not reach it in 2024. A reader who instead treats section 四 as replacing what section 一 says of 1E101.b would read coverage as reduced, which the text does not compel and which would make section 一 surplus. The tungsten metal page covers how those entries fit together, and the eleven announcements the list repealed are mapped in the note on them.

Dates

Methodology

Both texts are read in the original Chinese. The list entry is 1C117.c of Annex 1 to Announcement No. 51 of 2024, read from the 141-page PDF attached to that announcement, because the landing page carries no entry text. The February text is Announcement No. 10, read in full; the comparison uses sections 一（一）（二）（三）（四） and 四（一）（二）. The comparison was made clause by clause on 1C117.c; the only substantive change found in that entry is the purpose clause, alongside the addition of customs reference codes. The claim that the omission was deliberate is offered as an inference with its alternative stated. The conformed edition of the list, as revised in February 2025, was not available to this page, so the statement that the announcement governs rests on the announcement’s own closing sentence rather than on a copy of the revised entry.

Sources

商务部、工业和信息化部、海关总署、国家密码局公告 2024 年第 51 号，《两用物项出口管制清单》附件 1，1C117 条，2024-12-01 施行。 https://www.mofcom.gov.cn/zcfb/dwmygl/art/2024/art_e56833e346534981b250bae772d0cbce.html

商务部、海关总署公告 2025 年第 10 号，对钨、碲、铋、钼、铟相关物项实施出口管制，2025-02-04。 https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_e623090907fc4e1092f0a4db72f57b95.html