Industrial Policy & Trade Monitor· 2665 actions· ✨ 90 recent

China's Ministry of Foreign Affairs announced on 26 December 2025 that it is imposing countermeasures under Articles 3, 4, 5, 6, 9 and 15 of the Law of the People's Republic of China on Countering Foreign Sanctions against 20 US defense-related companies and 10 senior executives, in response to the Trump administration's 18 December 2025 announcement of roughly $11.1bn in arms sales to Taiwan — the largest single US weapons package for the island to date. Measures freeze the named entities' assets within China, prohibit organizations and individuals in China from transacting or cooperating with them, and deny visas/entry to the named executives. This is a Foreign Ministry Anti-Foreign Sanctions Law designation, distinct in legal basis from MOFCOM's parallel Unreliable Entity List mechanism used in prior 2025 Taiwan-arms-sale tranches (e.g. the 9 April 2025 six-firm UEL listing).

The National Defense Authorization Act for Fiscal Year 2026 (P.L. 119-60), signed into law on 18 December 2025, expands the Department of Defense's existing "covered materials" domestic- sourcing restriction (which already barred DoD contracting for SmCo/NdFeB magnets, tantalum and tungsten sourced from China, Russia, Iran or North Korea) to add gallium, germanium and molybdenum under Section 844. Restrictions on materials "melted or produced" in a covered nation take effect 31 December 2026, widening on 1 January 2027 to also cover materials "mined, refined, or separated" in a covered nation; the gallium/germanium additions specifically phase in on 18 December 2027. The same NDAA bundles two related supply-chain provisions: Section 867 gives DoD broader authority (contracts, grants, other-transaction agreements, equity-style investments, and anti-market-manipulation subsidies) to invest in the domestic industrial base for critical minerals, microelectronics, machine tools and other defense-relevant capacity, and Section 842 bars DoD from procuring advanced batteries whose cells or key components are owned, sourced, refined or produced by a foreign entity of concern, phased in 2028-2031.

On 18 October 2025 the Seimas of the Republic of Lithuania adopted a package of amendments to the Defence and Security Industry Law (XIV-2647, originally adopted May 2024), the Law on Public Procurement in Security and Defence, the Law on Control of Weapons and Ammunition, and cross-cutting territorial-planning and construction laws. The central measure, proposed by the Ministry of Economy and Innovation (EIMIN), replaces the full construction-permit requirement for defence-production facilities with a notification-of-commencement procedure, compressing typical procurement-to-groundbreaking timelines from approximately 2–2.5 years to a few months. Complementary provisions reserve public-land investment plots for defence projects, enable defence-industry development outside designated military territories, and enshrine industrial cooperation as a procurement principle requiring foreign OEMs fulfilling Lithuanian defence contracts to source a defined share of obligations from Lithuanian-registered entities. The package directly enables inbound defence-industrial FDI from Rheinmetall (155 mm artillery-shell JV) and the Northrop Grumman / Nammo medium-calibre ammunition programme at the state-owned Giraitė Armament Factory.

China's Ministry of Commerce on 9 October 2025 issued Announcements No. 61 and No. 62, jointly constituting the largest single architectural escalation of PRC export controls to date. No. 61 expands the controlled rare-earth list from 7 to 12 of 17 elements (adding holmium, erbium, thulium, europium, ytterbium) and — for the first time — imposes extraterritorial application via a 0.1% de-minimis rule, a foreign-direct-product (FDP) rule, and a 50%-affiliate rule, directly mirroring US BIS architecture. No. 62 places rare-earth extraction, smelting, separation, magnet manufacturing, and recycling technologies (including IP licensing, investment, and provision to foreign persons) under export licensing. PRC-direct exports were controlled from publication; the de-minimis and FDP offshore-items provisions were due to take effect 1 December 2025. On 7 November 2025 MOFCOM Announcement No. 70 suspended both measures until 10 November 2026 as part of the post-APEC Trump-Xi tariff detente — see amendments block.

China's Ministry of Commerce and General Administration of Customs announced on 4 April 2025 export licensing requirements on seven medium and heavy rare-earth elements: samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium. Exporters must apply for individual licences citing the end-user and end-use, with licences granted at MOFCOM's discretion. The announcement came two days after the 2 April Trump reciprocal-tariff package and was widely interpreted as a proportional response. Unlike the December 2024 Ga/Ge/Sb ban this is not US-specific on its face — but in practice licence approvals through April-June 2025 were heavily skewed away from US-bound shipments.

The Defence Trade Controls Amendment Act 2024 (C2024A00021) received Royal Assent on 8 April 2024 and created three new criminal offences in the Defence Trade Controls Act 2012: section 10A (supply of Defence and Strategic Goods List technology in Australia to a non-exempt foreign person); section 10B (secondary supply of DSGL Part 1 Munitions or Part 2 Dual-Use Sensitive/Very Sensitive goods or technology outside Australia when originally exported from Australia); and section 10C (provision of DSGL Part 1 services to foreign nationals outside Australia). All three offences carry maximum penalties of 10 years imprisonment or 2,500 penalty units (~A$782,500), or both. The offence framework commenced 1 September 2024 with a six-month compliance-transition period; criminal liability attached from 1 March 2025. The Act also codifies AUKUS-partnership exemptions, carving out supplies to and from citizens and permanent residents of the United Kingdom and United States, underpinning the licence-free trilateral technology-transfer environment sought under AUKUS Pillar 2.

The Department of Commerce Bureau of Industry and Security (BIS) added 91 entities (across 96 entries) to the Entity List under 15 CFR Part 744, in direct response to Russia's further invasion of Ukraine on 24 February 2022. The listed entities span ten destinations — Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and the United Kingdom — and include Russian military research institutes, shipbuilding facilities, aerospace and electronics manufacturers, and suspected front companies in third countries used to circumvent EAR controls. A license is required for all items subject to the EAR; the review policy is denial for 86 entities and case-by-case (for US Government-supported space programs) for five.