Reaching out to all experts out there in this forum are these statements here viable? Could this new regulation really harm Lynas?

Breaking: China Proposed Regulations on "Administrative Measures for the Total Control of Rare Earth Mining, Smelting and Separation"

Rare Earth 21 February 2025 #168

FEB 20, 2025

Intro

We had warned not to look at China as a large trash can for all things rare earth. Now things may be changing.

Before any of the junior miners starts hyperventilating again, these are PROPOSEDregulations for PUBLIC COMMENT. This is NOTan implementation. The comment period ends on 21 March 2024. At which time the regulation will not go into effect immediately, but public comments will be considered.

What it means

However, this proposed regulation means that - if this PROPOSED regulation ever goes into force - it will be the end of unregulated imports of rare earth raw materials and processing thereof.

Impact on junior rare earth miners

Concretely, if you are a junior rare earth miner who wants to produce a rare earth concentrate, mixed rare earth carbonate or a mixed rare earth oxide, your product can only be imported to China if your customer also has a quota for processing the relevant quantity.

To put it even more bluntly: If you are a junior rare earth miner, you’d better have a customer in the West for your product, because it will be anything but certain that you can place your quantities on the China market.

You are of course free to stir your product in your morning coffee.

Our take

If implemented this regulation will effectively cull all junior rare earth miners out there. Unless, they have a behemoth Chinese rare earth company as shareholder, then the respective junior rare earth miner will be fine.

Who will benefit

Western rare earth companies which do include processing of rare earth resources to final, usable, market adequate rare earth compounds and metals.

In Australia that would likely be Iluka and Arafura, in the U.S. Energy Fuels and Rare Element Resources. Subject to further analysis in Canada SRC, in Europe Neo Performance Materials.

Who will suffer

Anyone who ships rare earth raw materials, finished and semi-finished rare earth to China.

Subject to further analysis, affected may be Lynas, MP Materials, all artisanal miners in Africa, Serra Verde in Brazil and all junior rare earth miners who had been banking on the rare earth trash can in China.

Below please find the announcement of the Ministry of Industry & Information Technology and the appendices

https://treo.substack.com/p/breaking-china-proposed-regulations