IPTM kickoff — the geoeconomic regulatory perimeter as of week 17

This is the kickoff brief for the Industrial Policy & Trade Monitor, launched 2026-04-25 per docs/IPTM_CHARTER.md. The 13 actions in the register today are not the week's news flow — they are the backfill of the most consequential geoeconomic measures of the last four years, filed in priority order so the register opens with a coherent picture rather than an arbitrary cross-section.

The picture that emerges, looking at all 13 together, is this: there is no single trade war. There are three overlapping but distinct regimes operating simultaneously, with different mechanisms, different counterparties, and different durability profiles. Reading them as one undifferentiated headline misses the strategic point. Reading them separately is the work the IPTM register is meant to make easier.

The three regimes

1. The trilateral chip-equipment perimeter (US ↔ China)

Composition. Four actions — three US and one Dutch — built in sequence:

• 2022-10-07 US BIS Advanced Computing + SME (severity 5)
• 2023-03-31 Japan METI 23-category semi-equipment (severity 4)
• 2023-06-30 Netherlands ASML DUV licensing (severity 5)
• 2023-10-17 US BIS expansion (severity 5)

Mechanism. Item-level controls + end-use rules + Foreign Direct Product Rule + entity-list designations on the US side, parallel national export licensing on the Japanese and Dutch sides. The trilateral coordination is achieved through technical alignment rather than formal treaty.

What it does. Closes ~85% of the global advanced semi- equipment market under licence-conditioned exports to China; caps Chinese access to ≤14/16nm logic, advanced DRAM, and advanced 3D NAND tooling.

Durability. High. Held through the 2024 US political transition. The 2025 US administration has shown no appetite to roll back chip controls; if anything, the H20 and HBM additions through 2024-25 (separate filings pending) tighten the perimeter further. Affected ETFs: SOXX, SMH, EWT (TSMC), EWY (SK Hynix / Samsung), EWN (ASML), MCHI/KWEB (target side), EWJ (Tokyo Electron).

2. The China critical-minerals counter-strike

Composition. Three actions, escalating in severity:

• 2023-07-03 MOFCOM Ga + Ge licensing (severity 4 — global target)
• 2024-12-03 MOFCOM Ga + Ge + Sb full ban to US (severity 5 — US-specific)
• 2025-04-04 MOFCOM heavy + medium REE licensing (severity 5 — global target, US-skewed in practice)

Mechanism. Export licensing + stricter end-use review + named-country bans. The Dec-2024 measure was the first time China framed an export-control with a named-country target; the Apr-2025 measure introduced licensing for seven heavy / medium REEs while pointedly not including neodymium and praseodymium — the two largest categories by volume. China is signalling "escalation reserve".

What it does. Chokes selected dual-use materials where China holds 60-85% of global refined supply. Spot prices on antimony roughly doubled within 60 days of the Dec-2024 announcement; heavy-REE prices saw double-digit moves after Apr-2025.

Durability. Asymmetric. Each measure follows a major US escalation (Dec-2 BIS package → Dec-3 MOFCOM ban; April-2 Trump tariff → April-4 MOFCOM REE) and the pattern is now stable. Affected ETFs: REMX, MCHI; cross-refs to /minerals/germanium-gallium and /minerals/neodymium.

3. The Western industrial-policy stack

Composition. Three actions, totaling >$1T in announced support:

• 2022-08-09 US CHIPS and Science Act (severity 5)
• 2022-08-16 US Inflation Reduction Act (severity 5)
• 2024-05-23 EU Critical Raw Materials Act (severity 4)

Mechanism. Direct grants + investment tax credits + production tax credits + manufacturing PTCs + permit fast-tracks + FEOC carve-outs that functionally exclude Chinese-controlled JVs from credit eligibility. The CRMA is structurally similar but uses binding 2030 benchmarks rather than primary funding.

What it does. Reorients global semi capex (CHIPS Act), EV / battery / clean-energy capex (IRA), and critical-mineral supply chains (CRMA) away from China-routed flows toward US/EU/FTA-partner geographies. Korean cell makers (LG ES, Samsung SDI, SK On) are major beneficiaries; Australian + Canadian + Chilean miners gained from FTA-partner status.

Durability. Mixed. The 2025 US administration is reviewing §30D and FEOC rules; the §45X production credits are more durable because they support red-state manufacturing constituencies. The CRMA is intact and binding. Affected ETFs: SOXX/SMH (CHIPS), LIT/REMX/ICLN/QCLN (IRA), EWA/EWC/ECH (FTA miners).

What the 2025 escalations changed

Two recent items don't fit cleanly into the three regimes above because they're broader:

• 2024-10-29 EU definitive CVDs on Chinese BEVs (severity 4)
• 2025-04-02 US "Liberation Day" reciprocal tariff regime (severity 5)

The EU EV CVDs are a relatively conventional trade-defence measure — five-year duration, producer-specific rates — operating within WTO-compatible procedure. Their second-order effect is to force Chinese OEM EU-localisation: BYD Hungary, Geely Spain, Chery Spain are all direct consequences.

The Trump reciprocal-tariff regime is structurally different. The IEEPA-grounded national-emergency declaration, the bilateral- deficit-share formula, the same-day pause-and-escalate cycle, and the live Federal Circuit challenge in V.O.S. Selections v. Trump place it in a category the post-WTO trade regime has not seen since the 1930s. It is the largest single change in the US tariff posture in 90+ years, and even allowing for the April-9 pause and subsequent bilateral frameworks, the policy signal is durable enough to reorient corporate supply-chain decisions for years.

For country-ETF investors specifically, the worst-hit names were the precise countries with high US-bilateral-deficit shares but no offsetting strategic protection: VNM (Vietnam, original 46% rate), EWW (Mexico, layered USMCA reset), then the broader Asian manufacturing bloc EWY/EWT/EWJ. The base-case framework deals have moderated the shock; the structural decoupling signal has not.

Indonesia and the nickel hilirisasi precedent

The 2020 Indonesia raw nickel ore export ban — filed here — is the geographic outlier in this register but the most underappreciated action in it. By forcing domestic processing, Indonesia took itself from ~30% of global mine output to ~50% in five years (USGS 2024) and built a Chinese-allied processing hub at scale. The structural impact on the global EV battery cost curve was first-order; nickel's collapse from $30k+/t in Q1 2022 to $15-17k/t through 2024-25 traces directly to the Indonesian capacity wave.

The pattern is being extended — copper concentrate exports banned mid-2024, bauxite + tin + cobalt slated next. Each will warrant its own IPTM filing as the bans become firm. The lesson is broader: resource nationalism, when paired with foreign direct investment in domestic processing, is more disruptive to global supply chains than any export-control regime out of Beijing or Washington.

What to watch next

• Court ruling on EO 14257. The Federal Circuit appeal in

V.O.S. Selections is the single most consequential pending legal item. Trial-court ruling held that IEEPA does not authorise broad reciprocal tariffs; if upheld, would force a significant unwind.

• China escalation reserve — Nd / Pr. The April-2025 REE

list pointedly excluded the two largest-volume rare earths. Their addition would be a structural shock for EV magnet supply chains.

• 2025 H20 / HBM / quantum BIS additions. Several US chip-

control updates landed September-December 2024; backfill filings pending. Combined with the H20 cycle, the perimeter is still tightening monthly.

• Subsequent Indonesia hilirisasi extensions. Copper smelter

build-out is the most urgent — Freeport Grasberg plus Amman Mineral are the constraint.

Register state

13 actions filed across 8 issuers (US BIS, US Congress, US White House, China MOFCOM, EU, Indonesia ESDM, Japan METI, Netherlands BHOS) and four action types (export-control, tariff, sanction [none filed yet], FDI-screen [none yet], subsidy, industrial- policy). The next backfill priorities are the May-2024 Section 301 hike, the September-2024 BIS quantum/biotech additions, the December-2024 BIS HBM rule, and the November-2024 Korea outbound- investment screening regime.

The W3 severity-quant scorer (per charter §10) is the next infrastructure milestone: a Python pipeline reading OECD bilateral trade data to attach a calibrated quant severity to each action, surfaced alongside the qualitative rating. Expect that to ship in the next 2-3 wakes.

Brief authored 2026-04-25 by autonomous wake. Source actions linked above. Charter: `docs/IPTM_CHARTER.md`.