I call BS on the claim nuclear grade graphite is a “controlled material”. Nuclear grade graphite is nothing more than high purity material, with low quantities of elements that can be transmuted by nuclear reactions. That same purity makes it suitable for use in the semiconductor materials industry: graphite susceptors used to hold crucibles that hold liquid silicon, graphite parts used in reactors that decompose gases to make silicon etc, etc.
C.W.
https://dsgl.defence.gov.au/dsglcontent/Pages/0C004.aspx
According to DoD, the following type of Graphite is on DSGL(Defence and Strategic Goods List.)
0C004 Graphite having a purity level of less than 5 ppm (parts per million) boron equivalent and with a density greater than 1.50 g/cm3 for use in a nuclear reactor specified by 0A001.a., in quantities exceeding 1 kg.
N.B.: SEE ALSO 1C107
Note 1: For the purpose of export control, the Government will determine whether or not the exports of graphite meeting the above specifications are for nuclear reactor use.
Note 2: In 0C004, boron equivalent (BE) may be determined experimentally or is calculated as the sum of BEz for impurities (excluding BEcarbon since carbon is not considered an impurity) including boron, where:
BEZ (ppm) = CF x concentration of element Z in ppm;
where CF is the conversion factor:
and sB and sZ are the thermal neutron capture cross sections (in barns) for naturally occurring boron and element Z respectively; and AB and AZ are the atomic masses of naturally occurring boron and element Z respectively.
Sorry, that is not U.S. DoD, but Australian Dept. of Defense.