In the 2026 edition of its Inventory of Export Restrictions on Critical Raw Materials (28 April 2026, data through end-2024), the OECD reports that export restrictions on critical raw materials have reached a record high: 16% of monitored raw material trade faced at least one restriction between 2022 and 2024. China's two waves of rare-earth export controls (April and October 2025) make that vulnerability acute for Dutch high-tech, offshore wind, machine building and defence suppliers. Core action: map raw material exposure and origin now, before China's suspension expires in November 2026.
What is factually happening
On 28 April 2026 the OECD published the annual update of its Inventory of Export Restrictions on Critical Raw Materials, analysing measures through end-2024. The key findings (confirmed fact, level A):
- Export restrictions on critical raw materials have increased fivefold since 2009 and stand at an all-time high.
- The growth of new restrictions slowed from 3.4% in 2023 to 0.6% in 2024, but a wider group of countries — particularly in Africa and Asia — introduced new measures.
- Restrictions on ores and minerals (the upstream inputs in the chain) increased tenfold between 2009 and 2024.
- Between 2022 and 2024, 16% of the raw material trade monitored by the OECD faced at least one export restriction; for cobalt and manganese this was around 70%.
- Highly restrictive measures (export prohibitions and quotas) accounted for more than one-third of new measures in 2024. Generating government revenue became the most cited rationale, explaining nearly half of measures.
The OECD points to persistent concentration: the top three producing countries together account for more than two-thirds of cobalt, lithium and nickel, and nearly 90% for rare-earth elements. China alone produces around 70% of global supply of rare-earth elements and graphite.
In parallel, China escalated its export controls in 2025. On 4 April 2025 China introduced controls on seven heavy rare-earth elements plus related compounds and metals (IEA). A second wave on 9 October 2025 added five REEs, related products, equipment, technology and even personnel expertise; most measures were to take effect on 8 November (European Parliament / EPRS). On 7 November 2025 China announced a temporary suspension of the second wave, until 10 November 2026 (EPRS).
Structural drivers
The figures describe not an incident but a structural shift in the trade regime around raw materials. Three drivers sustain the trend.
Geopolitics and concentration. According to the IEA, China's share of sintered permanent magnet production has risen over two decades from around 50% to 94% today — the magnets that power the strongest motors in cars, wind turbines, industrial motors, data centres and defence systems. That concentration gives one country structural leverage.
Regulation as counterforce. The EU responds with the Critical Raw Materials Act. In March 2025 the Commission selected a first batch of strategic projects; five of them — in France, Italy, Poland and Sweden — cover the REE value chain from extraction to recycling (EPRS). This capacity does not yet exist, however; the effect is multi-year.
Extraterritorial reach. The most far-reaching element of the October wave: foreign firms would need approval to export magnets containing even trace amounts (0.1%) of Chinese-sourced REEs, or produced using Chinese mining, processing or magnet-making technologies (EPRS). For the first time, Chinese law would apply extraterritorially. This measure is now suspended, but the design is on the table.
Who is directly affected
First-order impact falls on processors and OEMs with rare-earth elements and permanent magnets in their product. The European Parliament notes production stoppages reported in the automotive sector following the controls (confirmed operational impact, level B). Others in the direct risk zone:
- Offshore wind: NdFeB magnets in generators of direct-drive turbines.
- Electric motors and EV drivetrains: automotive suppliers and machine building.
- Semiconductor and high-tech production: specialised materials and optics.
- Defence and aerospace suppliers: superalloys and magnets.
Probably not first-order affected: service providers, software firms, and manufacturers without REE or critical-metal content in their bill of materials. Note the condition: they can still be affected indirectly via price surcharges from suppliers, or when they switch to components with magnet content upon contract renewal. According to the EPRS, the ECB estimated that over 80% of large European firms are no more than three intermediaries away from a Chinese REE producer — an indication that "no direct exposure" rarely means "no exposure".
The second-order effect
The chain procurement must follow:
Direct event — export restrictions on critical raw materials at a record high (OECD) plus Chinese REE controls → First order — processors/OEMs with magnet and REE content report licensing pressure and, in the auto industry, reported production stoppages → Second order — suppliers may pass additional costs, longer lead times or origin documentation to buyers without their own China relationship → Condition — this effect becomes more likely if the suspension is not extended after 10 November 2026, or if the extraterritorial 0.1% rule is nonetheless activated → Procurement indicator — track licensing lead times at suppliers, price surcharges on magnet-/REE-bearing components, and requests for origin declarations.
This is an expected second-order effect (level C), not a certainty. The current suspension dampens the acute pressure; the structural exposure remains.
Dutch procurement impact
As an importing nation and transit hub, the Netherlands is doubly exposed. Rotterdam and the Rhine corridor form the supply route for ores, metals and semi-finished goods towards both Dutch and German manufacturing; upstream disruptions carry through to machine building, agri-food technology, chemicals, high-tech and offshore. The impact is partly direct (firms with REE/magnet in the bill of materials), partly indirect (via German and EU supply chains), partly possible (if the suspension expires).
Contract clauses
Assess whether current supplier contracts contain force-majeure and export-control clauses that cover third-country restrictions. Have it recorded who bears the risk in the event of a licence refusal and what origin documentation the supplier must provide. Company exposure: not yet calculated — link spend and supplier data.
Supplier conversations
Ask suppliers of magnet- or REE-bearing components explicitly about origin down to the mining step and whether their product would fall under China's 0.1% threshold or technology requirement if it is reactivated. This is not a theoretical question: the design of the rule exists.
Sourcing mix
Alternative sources are not interchangeable. The EU CRMA projects in France, Italy, Poland and Sweden are multi-year and do not yet cover volume. Weigh second sources on qualification lead time, magnet quality, price and security of supply — no ready-made shortlist, but a benchmark on these criteria.
Claim defence
Expect suppliers to invoke export restrictions to justify price increases or surcharges. Request substantiation: which material, which restriction, which date, which material share in the end product. Raw material % is not equal to product %; have the share made explicit before accepting a surcharge.
Budget/risk
Model a scenario in which the suspension is not extended after 10 November 2026. Quantify which share of spend is REE- or magnet-sensitive and what margin impact a price surcharge would have. This is scenario planning, not a forecast.
What is established and what is still uncertain
What is established (level A/B): the OECD figures on the record high, the fivefold increase since 2009, 16% of monitored trade and around 70% for cobalt/manganese (2022–2024); China's two control waves of 4 April and 9 October 2025; the suspension until 10 November 2026; China's ~70% share in REE and graphite and 94% share in sintered magnets; reported production stoppages in the automotive sector.
What is still uncertain (level C): whether the suspension will be extended; whether the extraterritorial 0.1% rule will nonetheless be activated; the precise price and lead-time impact on individual Dutch supply chains; and the degree of pass-through to buyers without a China relationship. Primary confirmation of company-specific effects in the Netherlands is lacking.
What to watch (measurable indicators): licensing lead times at suppliers, price surcharges on magnet-/REE-bearing components, requests for origin declarations, and reporting on an extension or termination of the Chinese suspension towards November 2026.
What you can do now
- This month — Category manager: have your own bill of materials screened for REE and permanent-magnet content (offshore, motors, high-tech, defence) and request in writing from the relevant suppliers the origin down to the mining step. Then decide which suppliers get an in-depth conversation.
- This month — Procurement + legal: have the force-majeure and export-control clauses in the top-10 REE-sensitive contracts reviewed with the supplier; record who bears the risk in the event of a licence refusal. Decide whether renegotiation is needed.
- This quarter — Sourcing lead: request a qualification indication from two alternative suppliers (lead time, magnet quality, price, origin) and benchmark against the current source. Decide whether qualification starts.
- This quarter — Category manager: from suppliers invoking export restrictions as grounds for a price increase, request the full substantiation (material, restriction, date, material share). Decide per claim on acceptance, dispute or a phased arrangement.
- This year — Procurement director: with finance, model a scenario "suspension not extended after 10 November 2026", including spend share and margin impact. Decide on inventory or contract cover.
How Orbecta supports
Orbecta links this development to your own spend and suppliers. The Supply Risk Index maps country and corridor exposure for critical raw materials; Contract Intelligence reviews force-majeure and export-control clauses in your REE-sensitive contracts; Claim Check dissects supplier claims about export restrictions by material, date and material share; and Warroom Prep prepares the negotiation with alternative sources and scenarios around the November 2026 suspension.
Sources
Primary source: OECD — OECD Inventory of Export Restrictions on Critical Raw Materials 2026 — 28 April 2026. Primary source: OECD — press release "Critical raw materials face rising export restrictions, increasing risks to global supply chains" — 28 April 2026. Primary source: IEA — "With new export controls on critical minerals, supply concentration risks become reality" — 2025. Additional context: European Parliament (EPRS) — "China's rare-earth export restrictions" — 8 November 2025 / 24 November 2025.
Orbecta analysis based on the above sources.