Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

On June 8, 2026, the US Department of Defense published its annual update to the Section 1260H Chinese Military Companies (CMIC) list, adding 65 entities (17 new parent companies and 48 subsidiaries), bringing the total to approximately 188–200 designated entities. Major additions span EV and battery manufacturing (BYD, NIO, CATL), consumer internet (Alibaba, Baidu, Tencent), semiconductors (SMIC, YMTC, CXMT), solar (JA Solar, Trina Solar), biotech (BGI Genomics, WuXi AppTec), drones/robotics (DJI, Unitree, RoboSense), and telecoms (TP-Link). Effective June 30, 2026, DoD is prohibited from procuring goods, services, or technology directly from listed entities; effective June 30, 2027, the ban extends to indirect supply-chain procurement through prime contractors and all sub-tiers.

The Federal Acquisition Regulatory Council (DOD, GSA, and NASA) published a Notice of Proposed Rulemaking on 17 February 2026 (FR Doc 2026-03065, 91 FR 7223) implementing Section 5949(a) of the NDAA FY2023 (Pub. L. 117-263), which bars executive agencies from acquiring electronic products or services containing semiconductor components designed, produced, or provided by SMIC, CXMT, YMTC, or their affiliates. A Part B prohibition extends the restriction to "critical systems" whose subsystems incorporate covered semiconductors regardless of COTS sourcing. The comment period closed 20 April 2026; proposed prohibitions take effect 23 December 2027.

On 30 December 2025 the General Office of the Shanghai Municipal People's Government issued Hufubangui [2025] No. 20, a three-year action plan (1 January 2026 - 31 December 2028) to support the transformation and upgrading of advanced manufacturing. The plan sets quantitative targets — 100 new manufacturing enterprises with annual output above CNY 1 billion by 2028 (cumulative 600+), 500 new above-designated-size supply-chain enterprises, 100+ new national-level green factories, a robot density of 600 units per 10,000 workers, and 70%+ digital-equipment penetration — across next-generation electronics, intelligent connected new-energy vehicles, high-end equipment, advanced materials, green low-carbon and fashion consumer-goods industries, plus emerging bets on the low-altitude economy, commercial aerospace, embodied intelligence (robotics) and biomanufacturing. It is funded through tiered direct subsidies rather than tax relief: one-off R&D subsidies up to CNY 10 million, equipment/new-materials cost-share up to 30% of contract value (capped at CNY 20 million), technical- transformation loan/leasing interest support up to CNY 20 million cumulative, and 0.8-1.3% interest subsidies on component/material backup-inventory financing.

The Bureau of Industry and Security (BIS) issued an Interim Final Rule amending the Export Administration Regulations (EAR) to automatically extend Entity List, Military End-User List, and certain other restricted- party controls to any unlisted entity that is at least 50% owned — individually or in the aggregate — by one or more listed parties. The threshold is set to mirror the long-standing OFAC 50% rule. Published 90 FR 47201 (Sept. 30, 2025); effective Sept. 29, 2025. A Temporary General License covering pre-existing transactions with 50%-owned affiliates expired on Nov. 28, 2025. The rule was subsequently suspended for one year by BIS on Nov. 10, 2025 (FR Doc. 2025-19846) as part of the post-Busan US-China understanding.

On 17 September 2025 the General Office of the Shanghai Municipal People's Government issued Hufubangui [2025] No. 8, a five-year (26 September 2025 - 25 September 2030) state-aid framework to accelerate frontier-technology innovation and cultivate "future industries" across six domains — future manufacturing, future information, future materials, future energy, future space and future health. Targeted technology areas include cell and gene therapy, brain-computer interfaces, biomanufacturing, embodied intelligence (humanoid robotics/AI hardware), fourth-generation semiconductors, silicon photonics, 6G, neuromorphic computing, quantum technology, controlled nuclear fusion and regenerative medicine. Support is disbursed as tiered direct subsidies rather than tax relief, with named ceilings up to CNY 30 million per proof-of-concept/R&D platform and CNY 20 million per high-quality incubator or first-product/batch innovation award.

On 6 September 2024 the Dutch government announced an expansion of its national export-control measure on advanced semiconductor manufacturing equipment, bringing two additional ASML DUV immersion lithography systems — TWINSCAN NXT:1970i and NXT:1980i — under a Dutch national authorisation requirement for shipments to destinations outside the EU. The measure took effect on 7 September 2024 via a ministerial regulation published in Staatscourant 2024 no. 29008. Until this point those two older system variants were controlled extraterritorially through the US Foreign Direct Product Rule; the change transfers licensing authority from BIS to the Dutch government and aligns the Dutch national list more tightly with the perimeter set by the June-2023 measure on NXT:2000i+. ASML characterised the update as a "technical change" with no expected impact on its 2024 financials or longer-term outlook.

China registered the National Integrated Circuit Industry Investment Fund III Co., Ltd. ("Big Fund III") in Beijing on 24 May 2024 with RMB 344 billion (~USD 47.5 billion) of registered capital — the largest single capital raise of the three Big Fund phases (Phase I 2014: RMB 138.7bn; Phase II 2019: RMB 204bn). Nineteen state-owned investors contribute, led by the Ministry of Finance (17% / RMB 60bn) and the six largest state-owned commercial banks (ICBC, ABC, BoC, CCB ~6.25% each at RMB 21.5bn; BoCom RMB 20bn; PSBC RMB 8bn). Duration 15 years (24 May 2024 → 23 May 2039). The fund explicitly targets the chokepoints exposed by US BIS October 2022/2023/2024 controls — semiconductor manufacturing equipment, advanced memory (HBM/DRAM), AI accelerators, and third-generation compound semiconductors (SiC, GaN).

The Biden administration announced on 14 May 2024 a package of Section 301 tariff increases on Chinese imports following the four-year statutory review of the original 2018-2019 tariffs. The hikes target sectors central to the US-China industrial-policy contest: BEVs went from 25% to 100%, lithium- ion EV batteries 7.5% → 25% (with non-EV battery cells rising in 2026), battery parts 7.5% → 25%, natural graphite + magnets 0% → 25% (phased to 2026), semiconductors 25% → 50% (phased to 2025), solar cells 25% → 50%, steel + aluminum products in selected categories 0-7.5% → 25%, ship-to-shore cranes 0% → 25%, certain medical products 0-7.5% → 50%. USTR issued the final determination on 13 September 2024 with most items effective 27 September 2024.

President Biden signed Executive Order 14105 on 9 August 2023, "Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern", establishing the first dedicated US outbound-investment screening regime. The EO directs Treasury to prohibit or require notification of US investments in Chinese (and Hong Kong, Macau) entities engaged in three categories of technology: (1) semiconductors and microelectronics, (2) quantum information technologies, (3) artificial intelligence systems. After a public-comment process, Treasury issued the final rule (31 CFR Part 850) on 28 October 2024, effective 2 January 2025.

The Dutch government announced on 30 June 2023 a new national export-licensing requirement covering specific advanced semiconductor manufacturing equipment, most prominently ASML's TWINSCAN NXT:2000i and subsequent DUV immersion lithography systems used at ≤14/16nm logic, advanced DRAM, and advanced 3D NAND production. Effective from 1 September 2023 via the national Strategic Goods Decree, the rule completes the trilateral US-Japan-Netherlands chip-equipment perimeter initiated by the January 2023 trilateral agreement. Although nominally country-neutral, the BIS Foreign Direct Product Rule means licences for shipments to "countries of concern" — read: China — face a presumption of denial. Subsequent guidance in 2024 expanded coverage to additional TWINSCAN NXT:1970Ci and 1980Di system variants.

OFAC codified the Chinese Military-Industrial Complex Sanctions Regulations at 31 CFR Part 586, implementing Executive Order 13959 (November 12, 2020) as amended by Executive Order 14032 (June 3, 2021). The regulations prohibit US persons from purchasing or selling publicly traded securities of entities designated on OFAC's Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, which identifies firms determined to support the People's Liberation Army or Chinese surveillance-technology programs. A divestment deadline of June 3, 2022 applied to entities named in the original EO 13959 annexes; future additions carry a one-year divestment window from the date of designation.

The Bureau of Industry and Security added 77 entities (under 78 entries) to the Entity List via a December 22, 2020 final rule (FR Doc 2020-28031). The headline designation is Semiconductor Manufacturing International Corporation (SMIC) — China's largest contract chipmaker — for activities related to military-civil fusion (MCF), with a presumption of denial applied to all items uniquely required to produce chips at advanced nodes of 10 nanometers or below. The batch also covers entities that supported PRC militarisation of artificial islands in the South China Sea and entities implicated in human rights abuses against Uyghurs and other minorities in Xinjiang.