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New: Upcoming Catalysts table, based on ‘The Tape’ section.

We are looking forward to hearing your comments and feedback on it.

Executive summary (20-second highlights):

Chinese licenses are being issued again after long waits, and in the same week a handful of Chinese suppliers stopped shipping to U.S. customers altogether.
The instrument doing the work is not an export control. It is a sanctions listing aimed at the audit bodies your own contract obliges your supplier to work with.
A land commissioner closed a U.S. state to new uranium leasing on 4 September. Inside a day, a Brazilian judge shut the country's only producing lithium mine. Neither decision was taken by a national government, and neither is priced.
Three separate parties contracted rare earth feedstock this week on three continents, two of them closed scrap loops. The one government that has taken legal power over where that scrap goes still has not written the rule.
One privately held French refiner now sits inside the French, Japanese and Kazakh heavy rare earth plans at once. Nobody has drawn that picture, including the three governments in it.
The credential regime issued another non-binding letter this week. We then went looking for a single U.S. filing describing a cargo that did not arrive, across every form type, for all of 2026. There are none.

Illustration of China’s Ministry of Commerce (MOFCOM) headquarters

The licenses cleared, and the cargo stayed

China's hold on rare earths runs through an administrative permission system.

We covered this mechanism in the briefing edition CW27: export licenses became the ‘unit of supply’, because the marginal tonne moves when an official decides it moves. Every position built since then has been a position on that decision.

The November 10th expiry of the broad licensing suspension is the date the whole critical minerals market is watching, and the Erbium, Holmium and Ytterbium bid is a straight expression of it.

About three weeks ago, we covered in the CW33 briefing an assessment made by Argus Media, reporting that (i) Erbium had a price appreciation of ~50% in Europe and about ~40% in China since early June (2-month window), (ii) Holmium had an appreciation of ~25% in both markets, and (iii) Ytterbium an appreciation of about ~75%. Argus' rare earths pricing lead, Maeve Flaherty, put it down to market participants inside and outside China who believe export controls may be reimposed, cutting off supply to the rest of the world.

So far, so good.

But last Friday, Reuters reported two things in the same story, and the market has not fully internalized both:

First, several U.S. firms have recently received multiple licences after waits of more than six months, with some expecting approvals to pick up around the September summit (which apparently is good news, right?).
And second, a handful of Chinese suppliers have refused to ship rare earths to U.S. companies since early August, when China sanctioned the Responsible Business Alliance. One source described four instances of firms declining to send material out of concern it could be resold to a banned user. The specific materials are Yttrium, Terbium, Gallium, Tungsten, and Indium phosphide.

What is curious is that in the same week, export permits/licenses have loosened, while actual deliveries have tightened. And the CMJ community knows better which one actually moves the needle.

The fear of the material being redirected to banned users comes from the Chinese MOFCOM Order No. 2 of 2026, which placed six U.S. organizations on China's countermeasures list under Article 8 of the Anti-Foreign Sanctions Law, implementing provisions for assisting the United States' Xinjiang-related sanctions against Chinese companies. Two of the six are the Responsible Business Alliance and Verité Group.

The Responsible Business Alliance runs the audit and traceability apparatus that Western buyers wrote into their own procurement contracts: the Responsible Minerals Initiative conformance status, the Validated Assessment Program, and membership. A U.S. buyer's supply-chain compliance clause frequently requires its supplier to hold or maintain exactly those things. The order prohibits organizations and individuals inside China from "engaging in relevant transactions, cooperation and other activities" with the listed persons.

So, a Chinese supplier weighing an American order is looking at a customer contract it may not be able to perform without breaking Chinese law, and at a domestic informant scheme, live since July 1^st, that pays for reports of export-control violations.

Whatever the licensing office decides, it has one clean option: decline the order.

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China has stopped needing to refuse its export licenses.

It only has to make one very expensive to use (especially for the seller).

This is what we would call an 'unusable licence', and it is a different object from a denied one.

A denied licence is visible, dated, and attributable to a state (almost as if an ‘act of war’).

But an unusable licence sits in a drawer at a Chinese trading company while a U.S. buyer's procurement team files it as approved and waits for a container that is not coming.

The first is a policy event a market can price. The second is a counterparty decision that leaves no trace, no licence tally, or any official statement. It is a ‘business decision’, that we can only see its impacts on customs reports.

Which raises the obvious question: is anyone telling this to their investors?

We went to look. The table below is CMJ's own pull from the SEC's full-text search system, counting filings of every form type that contain both exact phrases. Bear in mind this is an exercise, made out of pure curiosity.

Sources: Critical Minerals Journal (CMJ) analysis (September 2026), from SEC EDGAR full-text search, exact-phrase conjunction, all form types, monthly windows. All-form counts are affected by filing seasonality: March and April carry annual-report season and May and August carry quarterly reports, so the annual shape is not readable and only the recent monthly direction is. February could not be retrieved and is not estimated. Non-exhaustive.

Two controls run on the same system, and these are the numbers that matter. In the August 31^st to September 7^th window, 138 filings name 'rare earth' at all. Five of those name an export license alongside it.

And the phrase 'declined to ship' appears in zero filings, of any form type, by any registrant, at any point in 2026.

Is this alarming? Not necessarily.

A publicly traded company can reasonably interpret a foreign supplier’s refusal to sell as an operational event and non-material.

The point here is that there is currently no public series measuring this. There are no easily accessible customs codes, license counting mechanisms, or mandatory disclosure.

Having a clear view of the market and deeply understanding its modus operandi is what will give you an edge.