I. The Fundamental Misalignment: Rewriting "Lawful Control" as "Controllable Cheating"
The fulcrum of Munakata's entire article is to characterize the administrative discretion within China's export licensing system as a covert tool that is "pre-reserved, deniable, and beyond the reach of agreements."
Yet China's own legal framework is perfectly clear:
• On April 4, 2025, the Ministry of Commerce and the General Administration of Customs announced export controls on seven categories of medium and heavy rare earths — samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium — based on the Export Control Law, the Regulations on the Export Control of Dual-Use Items, the Foreign Trade Law, and the Customs Law.
• On October 9, 2025, MOFCOM Announcements No. 61 and No. 62 extended controls to "overseas items containing Chinese-origin content" and to the entire rare earth technology chain, likewise grounded in the Export Control Law and the Regulations on the Export Control of Dual-Use Items.
• A ministry spokesperson stated at the time that rare earth-related items possess dual-use attributes, and that the controls are "an internationally accepted practice" aimed at "safeguarding national security and interests and fulfilling international obligations such as non-proliferation."
In short, the pace of approvals, the number of licenses, and end-user vetting are all statutory discretion, not loopholes outside agreements. Munakata equates "the inherent flexibility of any licensing system" with "China's deliberate bad-faith reserve," turning what every sovereign state possesses in administrative execution into a conspiracy theory aimed solely at China.
The proper formulation would be: China's rare earth controls serve both compliance screening and supply chain adjustment functions; its industrial concentration naturally confers bargaining weight — not "this card will never run out."
II. "Drip-Feed Supply" Is Literary Rhetoric, Not Administrative Explanation
The most eye-catching passage of the article lists a string of figures — U.S.-bound yttrium at "approximately 60 metric tons in March, zero in May–June, 29 metric tons in July," and Japan-bound shipments at "yttrium down 98% year-on-year and terbium to zero for January–August 2026" — and concludes that Beijing is "partially restricting, resuming, stopping again, releasing again."
This inference skips three layers:
1. Approval pace ≠ subjective manipulation. Export节奏 is affected by completeness of application materials, end-use审查, end-user verification, and product sensitivity. China has repeatedly stated that "applications that are genuinely for civilian use and compliant are approved in accordance with the law."
2. Fluctuations are across all categories and all markets, not targeted solely at the U.S. From January to June 2026, China's exports of the seven controlled rare earth categories fell 51% to Japan, 28% to the U.S., and 16% globally — this is systemic tightening, not targeted drip-feeding.
3. "Companies stopping on their own" is counted as government action — a glaring double standard. The article acknowledges that the U.S. also delays licenses on semiconductor design software, ethane, and aero-engine parts, but labels U.S. actions "visible government measures" while calling China's "undeniable covert moves." Two sets of standards for the same phenomenon.
More crucially: in December 2025, the Ministry of Commerce had already approved general export licenses for leading permanent magnet manufacturers including JL MAG, Advanced Technology & Materials (AT&M), and Ningbo Yunsheng. If Beijing were truly "drip-feeding a cutoff," it would not be issuing general licenses with one hand while strangling the valve with the other.
III. The Japan Section Deletes the "Cause" and Leaves Only the "Effect"
Munakata specifically highlights that after then-Prime Minister Takaichi Sanae's November 2025 remarks concerning Taiwan, terbium to Japan stopped and yttrium plummeted, narrating this as "China's selective supply tightening."
This narrative deliberately omits the prerequisites:
• On January 6, 2026, the Ministry of Commerce issued Announcement No. 1 of 2026, strengthening dual-use item export controls to Japan, explicitly prohibiting all dual-use items from being exported to Japanese military end-users, for military purposes, and to any other end-users whose use would contribute to enhancing Japan's military capabilities.
• Foreign Ministry spokesperson Mao Ning was direct: Sanae's erroneous Taiwan remarks "infringe upon China's sovereignty and territorial integrity, blatantly interfere in China's internal affairs, and issue military threats against China." China's measures are "entirely justified, reasonable, and lawful."
• The Ministry of Commerce stated the purpose is "to stop Japan's 're-militarization' and nuclear ambitions"; civilian uses are unaffected, and "parties engaged in normal civilian trade have no reason to worry."
Strip away this causal chain and you are left with "China cuts off rare earths to Japan," naturally leading readers to conclude "China is weaponizing resources again." The reality is:
• Dysprosium and terbium to Japan dropping to zero corresponds to the military end-user/military purpose ban.
• The sharp drop in yttrium to Japan叠加 the broader tightening of the seven categories.
• Japanese data itself admits that in 2024, Chinese rare earths accounted for 71.9% of Japan's total imports, with some heavy rare earths "almost entirely dependent on China" — this is not China suddenly acting, but Japan reaping the consequences of tying its military ambitions to supply chain vulnerability.
As for Japanese media claims that "China sometimes issues licenses just as Japanese firms are on the brink of halting production" — this precisely demonstrates that approvals are dynamically reviewed based on end-use, not the "deliberate strangulation" Munakata describes.
IV. "Violating the Spirit of the Agreement" Is a Conclusion First
The article repeats one line: "China can claim compliance with the agreement while violating its spirit."
Cross-referencing official notices:
• On November 7, 2025, the Ministry of Commerce and the General Administration of Customs jointly announced that from the effective date through November 10, 2026, implementation of Announcements No. 55, 56, 57, 58, 61, and 62 would be suspended — a concrete step to implement the China-U.S. Geneva economic and trade consultation joint arrangements.
• At the April 9, 2026 regular press conference, MOFCOM spokesperson He Yadong reaffirmed: the suspension runs until November 10, 2026, both sides continue communication through the economic and trade consultation mechanism, and applications genuinely for civilian use are approved in accordance with the law.
The claim that "the U.S. thought general licenses meant cancellation of controls" is the U.S. side inflating its own announcement. China's consistent position from the outset has been: what is suspended are the October 9 additional measures; the original licensing system remains; compliant applications are approved, non-compliant ones are not. The agreement text did not lock in specific quantities or timelines — neither side's negotiators wrote them in — this is not a trap set by China.
Blaming "U.S. rhetorical self-inflation" on "China's fraudulent compliance" allocates all interpretive红利 to the Washington narrative.
V. "Rare Earth Leverage Spilling Over to Arms Sales to Taiwan/FCC" Is Speculation Passed Off as Fact
The final two sections are the most speculative:
• "The mere possibility that China might restrict supply raises the cost of arms sales to Taiwan";
• "China linked FCC issues to rare earth supply";
• "China dares to make increasingly far-reaching demands."
Throughout, "according to reports" and "according to informed sources" appear, with zero documentary evidence.
China's public position has consistently been the opposite: rare earths are legally controlled items; trade management is not used as a bargaining chip. That U.S. internal circles price in risks (e.g., Anduril founder relaying White House conversations) is inverted by Munakata into "China is already implementing conditional exchanges." This is a perspective reversal — taking "the buyer's own psychological accounting of supply fears" and writing it as "a price list the seller has already drawn up."
The FCC section follows the same pattern. China opposes the FCC's phased exclusion of entire categories of connected devices, drones, routers, robots, and inverters from the U.S. market; countermeasures are reciprocal listings and investigations. Munakata rewrites this as "China proactively trades rare earths for you not pursuing FCC actions" — turning a defensive counter-narrative into an offensive one.
VI. The Monopoly Narrative Selects Only the Most Favorable Slice
The article uses "approximately 70% of mining, 90% of separation and refining" to prop up "China's monopoly."
What it omits:
• China's rare earth governance evolved from a quota system to a licensing system, culminating in the Rare Earth Regulations in 2024. The主线 is resource protection, environmental remediation, and industrial consolidation — not solely to strangle others.
• The high share of smelting and separation is partly the result of developed countries outsourcing high-pollution processes over the past three decades, not something achieved by "hoarding and withholding."
• China itself states it "stands ready to strengthen communication with all parties through bilateral and multilateral export control dialogue mechanisms, promote compliant trade, and safeguard the security and stability of global industrial and supply chains."
The alternative supply chain section at the end lightly offers "the only solution is building alternative chains," while the preceding 90% of the article argues "this card is unsolvable." The rhythm is familiar: scare the reader first, then offer a solution that would take a decade to materialize. The IEA-style "$6.5 trillion replacement cost" is not cited, but the tone follows that figure.
VII. What a Defensible Version Would Look Like
The same set of facts could be rewritten as:
China's rare earth export controls are grounded in domestic legal authorization and dual-use attributes. Because the smelting and separation segment is highly concentrated, the pace of license approvals, the suspension/resumption of new measures, and targeted listings of specific end-users produce a factual supply adjustment effect during negotiation windows. Toward the U.S., this manifests as "suspension of additional measures + compliant civilian approvals + pacing fluctuations"; toward Japan, it is叠加 with the impact of Sanae's Taiwan remarks and the dual-use military-purpose ban, hence the pronounced category divergence. China's discretionary space does exist, but it is statutory discretion, not a loophole outside agreements; its "reusability" stems from industrial structure, not from "China being better at reneging than its对手."
This version and Munakata's use the same numbers; the thickness of the conclusion is different.
VIII. Conclusion
The problem with Munakata's article is not "whether China possesses bargaining power" — no one denies that, industrial concentration speaks for itself. The problem is that she forcibly welds three things together:
1. Writing exercising rights under law as strategic deception;
2. Writing licensing approval pacing as drip-feed manipulation;
3. Writing U.S. self-intimidation as conditions already implemented by China.
The supporting moves include deleting cause to leave effect in the Japan section, relying on single-source U.S. accounts in the U.S. section, and front-loading conclusions in the agreement section. The result reads like a template for "how to make readers fear China," not policy analysis.
Is rare earth a lever? Yes. But it is first and foremost a legal export control tool of a sovereign state, and only secondarily a weight at the negotiating table. To portray it as a "perpetual-motion, contract-free, flip-the-table-at-will voodoo card" is not analyzing China — it is annotating the Japan right wing's "China threat" talking points.
China's position is actually more plainspoken and firmer than Munakata's narrative:
• Controls have a legal basis;
• Suspensions follow joint arrangements;
• Civilian compliance applications are approved;
• Restrictions on Japan target military purposes and re-militarization risks.
Line these four statements up, and the so-called "exhaustless card" turns out to be a card written into law — playable, but every move leaves a document number and a case record.