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Structured register of government actions in the geoeconomic space — export controls, tariffs, sanctions, FDI screening, subsidies, industrial-policy laws — cross-referenced into the country, minerals, and ETF surface. Charter: docs/IPTM_CHARTER.md.
Severity 1-5 is the qualitative impact rating (1=minor, 5=structural). The bilateral-trade-grounded quant scorer is the next IPTM milestone. RBI (Register Breadth Index) is a complementary structural-breadth indicator from scripts/py/iptm/breadth.py; divergence between RBI and severity is itself informative (high-sev / low-RBI = strategic chokepoint; low-sev / high-RBI = broad but shallow). Every action has at least one primary source URL. Verify-or-don't-file. See also themes, timeline, graph, sankey, map, country exposure, sector exposure, material exposure (+ graph), weekly briefs, portfolio scan, escalation monitor, trans-shipment hubs. Internal triage tools (RSS-poller candidate feed, source-feed health) live under /admin/candidates + /admin/sources. Subscribe via Atom feed (accepts ?country=CN, ?material=lithium, ?issuer=BIS, ?type=export_control, ?etf=SOXX, ?company=NVDA, ?minSeverity=4, ?year=2026, ?q=…) or pull /api/iptm/actions.
MOFCOM's Foreign Trade Division issued Trade Letter [2026] No. 404 on 29 September 2026, opening the annual declaration cycle for 2027 automobile and motorcycle export licences under China's 2012 export-order licensing framework. The online application system opens 30 September 2026 and local commerce departments must complete initial review and submit applications to MOFCOM by 28 October 2026. For the first time, all applicants — including Category A manufacturers and vehicle-modification producers — must submit a new "Overseas Compliance Management Commitment Letter" pledging to follow pricing regulations and refrain from disrupting market order to gain unfair competitive advantage; companies that miss the deadline or fail to submit required documentation lose eligibility for an export licence.
On 14 September 2026 the European Commission adopted a Delegated Regulation (reference C(2026)6323) amending Annex I of Regulation (EU) 2021/821 to add newly-controlled dual-use items implementing the 2025 multilateral cycle of the Wassenaar Arrangement, MTCR, Australia Group, and NSG. New entries include semiconductor fabrication equipment (atomic layer deposition, EUV inspection systems, wafer cleaning), advanced computing ICs with digital processing units, ceramic matrix composites, additive-manufacturing systems for energetic materials, and chemical vapor deposition equipment for silicon carbide fibre production. The regulation is not yet in force: it now enters the standard two-month European Parliament/Council non-objection scrutiny period before publication in the Official Journal.
China's Ministry of Commerce announced that drones, key drone components, and related technologies already listed on China's Dual-Use Items Export Control List will be subject to strict case-by-case review when exported to the United States, and will no longer be eligible for licensing-facilitation measures. The measure does not add new items to the control list or ban exports outright — it tightens the review standard and removes expedited-licensing treatment for existing listed drone items. MOFCOM said the move is a countermeasure responding to recent US actions, including the FCC's ban on imports of Chinese drones and DHS's addition of 43 Chinese companies to the Uyghur Forced Labor Prevention Act entity list.
China's Ministry of Commerce issued Announcement No. 30 of 2026 on July 24, 2026, adding 14 EU-based entities to the Export Control Management List under the Export Control Law and Dual-Use Items Export Control Regulations. The listing bars Chinese exporters from supplying dual-use items to the named entities, bars any overseas party from transferring or providing China-origin dual-use items to them, and orders ongoing related transactions to stop immediately; exporters may apply to MOFCOM for case-by-case exemption. It is the first MOFCOM entity-list action ever to target EU-domiciled entities and the first ever to name a university (Wrocław University of Science and Technology). The 14 entities span Germany (Rheinmetall AG, Sindlhauser Materials GmbH, Antraco Chemie-Handelsgesellschaft mbH), Italy (Lafert S.p.A., Garnet S.r.l.), France (InPACT S.A., III-V LAB, Cavok UAS), Poland (Vigo Photonics S.A., Politechnika Wrocławska), the Netherlands (IHC Merwede Holding B.V.), Czechia (TATRA TRUCKS a.s.), Bulgaria (Opticoelectron Group) and Lithuania (Ekspla UAB) — defence, drone, photonics, laser, semiconductor and maritime-engineering firms and research institutes. The action came roughly 24 hours after the EU's 21st Russia sanctions package (adopted July 23, 2026) added Chinese and Hong Kong dual-use-trading entities to its own restricted list, and is widely read as a reciprocal countermeasure.
On 29 June 2026 China's Ministry of Commerce issued Announcement No. 27 [2026], adding 20 Japanese entities to the dual-use-item export-control Control List (受控名单) under the Dual-Use Export Control Regulations. The designated entities include four defense research institutes (National Institute for Defense Studies plus ground-, naval- and air-systems research bodies) and 16 companies, primarily Mitsubishi Electric and Mitsubishi Heavy Industries subsidiaries. The Control List designation imposes an absolute prohibition on exporting PRC-origin dual-use items — including rare earths and gallium/germanium/antimony-class strategic minerals — to the listed parties, and bars any third-country transfer of Chinese-origin dual-use items to them; ongoing supply activity must cease immediately, with exceptions only via special MOFCOM application. MOFCOM stated the action targets entities "involved in enhancing Japan's military capabilities."
China's Ministry of Commerce issued Announcement No. 23 of 2026 on June 22, 2026, adding 10 US entities to the Export Control Management List under the Export Control Law and Dual-Use Items Export Control Regulations. The listing prohibits Chinese exporters from supplying dual-use items to these entities and bars any global party from transferring China-origin dual-use goods to them; ongoing transactions are suspended pending MOFCOM approval. The 10 entities include the two largest non-Chinese rare earth producers — MP Materials Corp. (Mountain Pass, CA) and USA Rare Earth Inc. (Round Top, TX) — as well as eight US defence firms (Aveox, Red Cat Holdings, Teal Drones, IMSAR, Jaia Robotics, Ball Aerospace, Oshkosh Defense, L3Harris Maritime). MOFCOM explicitly framed the action as retaliation for the US DoD's June 8, 2026 update to the Section 1260H Chinese Military Companies list, which added ~80 Chinese parent firms and 188 affiliates.
On June 17, 2026, BIS announced a $36,184,680 civil penalty settlement with Robert Bosch GmbH (Stuttgart, Germany) — the largest-ever BIS enforcement penalty against a non-US company for Foreign Direct Product Rule (FDPR) violations. Between September 16, 2020 and September 26, 2024, Bosch exported approximately $72.4 million in MEMS sensor products and automotive software from abroad to Huawei Technologies and its Entity List affiliates without the required BIS license. Bosch filed a Voluntary Self-Disclosure and cooperated throughout; the DOJ issued the first-ever NSD declination under its newly established Corporate Enforcement Policy, declining criminal prosecution entirely.
On 24 February 2026 China's Ministry of Commerce simultaneously issued Announcement No. 11 and Announcement No. 12 [2026], activating for the first time the Control List (受控名单) mechanism under Article 28 and the Watch List (关注名单) mechanism under Article 26 of the Dual-Use Export Control Regulations (effective 1 December 2024), designating 40 Japanese entities in total. The Control List (20 entities, led by Mitsubishi Heavy Industries Shipbuilding Co.) imposes an absolute prohibition on any person or entity worldwide supplying PRC-origin dual-use items to listed parties; the Watch List (20 entities, led by SUBARU Corporation) bars general licensing and requires exporters to file risk assessments and non-military-use commitments. MOFCOM framed both measures as a response to Japan's "remilitarization" trajectory, escalating well beyond the blanket enhanced- review framework established by Announcement No. 1 [2026] in January.
The US Bureau of Industry and Security issued a final rule (RIN 0694-AK43, 91 FR 1684, signed 13 January 2026, effective 15 January 2026) revising the EAR license-review policy for exports of certain advanced-computing integrated circuits to end-users in China and Macau from a presumption of denial to case-by-case review. Eligibility is limited to commodities controlled under ECCN 3A090.a and 3A090.b with a Total Processing Performance (TPP) below 21,000 and total DRAM bandwidth below 6,500 GB/s — the band that covers NVIDIA H200 and AMD MI325X-equivalents and below. To qualify, exporters must certify (i) sufficiency of US supply such that the export will not delay domestic orders or divert foundry capacity, (ii) that aggregate TPP of advanced-node ICs exported to China or Macau will not exceed 50% of domestic shipments, (iii) compliance with end-use and end-user prohibitions, and (iv) prior performance review by a qualified independent third-party testing lab headquartered in the United States. The rule is the first material rollback of the October 2022 / October 2023 / December 2024 advanced-computing export-control architecture and operationalises the Trump-administration policy of trading H200-class chip access against Chinese cooperation on critical minerals, fentanyl precursors and Taiwan-strait restraint.
On 6 January 2026 China's Ministry of Commerce issued Announcement No. 1 [2026] "On Strengthening Export Controls on Dual-Use Items to Japan" (商务部公告2026年第1号), the first PRC export-control instrument to single out a named country other than the United States. Effective immediately on publication with no wind-down period, the measure prohibits export of all dual-use items under PRC export-control law where the end-user is the Japanese Ministry of Defense or Self-Defense Forces, the end-use is Japanese military, or — under a novel catch-all standard — the transaction would "enhance Japan's military capabilities." The standard is explicitly extraterritorial, covering transfers of PRC-origin dual-use items through third countries and in-country transfers where the end-user / end-use falls within scope. The political trigger was Japanese PM Takaichi's November 2025 Diet remarks framing a Taiwan contingency as a Japanese "survival-threatening situation" justifying SDF deployment.
Decision No. 582 of 2025 of Egypt's Ministry of Investment and Foreign Trade, published in the Egyptian Official Gazette (Issue 4 bis) on 5 January 2026, carves a narrow, fee-bearing exception into Egypt's standing export ban on raw white silica sand (originally imposed by Prime Ministerial Decree No. 108 of 2022). Shipments of raw white sand destined for production projects established inside Egypt's free zones are now permitted, but only within quantities approved by the General Authority for Investment and Free Zones (GAFI) and subject to a new export duty of US$15 per metric ton (or the EGP equivalent). Outside this free-zone exception, the general export ban on the material remains in force.
On 31 December 2025, China's Ministry of Commerce and General Administration of Customs jointly published Announcement No. 91 of 2025, releasing the 2026 edition of the Catalogue of Dual-Use Items and Technologies Subject to Import and Export Licence Administration, effective 1 January 2026. The update replaces the 2025 catalogue and is issued under the Export Control Law of the PRC and the Regulations on Export Control of Dual-Use Items. Key additions to the export-licensing perimeter include samarium, gadolinium, and lutetium compounds — mid-to-heavy rare earths critical for permanent magnets (EV motors, wind turbines), phosphors (medical imaging, displays), and defence applications — requiring MOFCOM export licences for all covered shipments from 1 January 2026.
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.
The UK Export Control (Amendment) (No. 2) Regulations 2025 (SI 2025/1197) entered into force on 16 December 2025, extending the UK's strategic export control regime to cover quantum computing hardware (ECCN-aligned 4A506), advanced and cryogenic semiconductor technologies (3A501, 3A504, 3B501), and associated software and technology categories. The regulations also transfer existing national controls on quantum and advanced semiconductor items from the Export Control Order 2008 into the UK's assimilated Dual-Use Regulation (retained EU 428/2009 as amended), harmonising the UK's dual-use schedule with Wassenaar Arrangement 2024 updates. The action is explicitly calibrated as "Wassenaar Minus One" — aligning UK controls with the US BIS (EAR / ECCN framework) and EU (Regulation 2021/821 as amended) without requiring multilateral consensus on each item. It is the first UK statutory instrument since Brexit to add substantial new technology-specific dual-use controls targeting advanced semiconductor and quantum capabilities.
On 11–12 December 2025, China's National Development and Reform Commission (NDRC) convened a special meeting with major phosphate fertiliser producers, traders, and industry associations, instructing them to suspend phosphate fertiliser exports in principle until August 2026 to concentrate supply on the domestic market and stabilise prices ahead of the 2026 spring planting season. The measure covers diammonium phosphate (DAP), monoammonium phosphate (MAP), triple superphosphate (TSP), and compound NPK fertilisers. China supplied roughly 40% of global phosphate fertiliser exports before the ban; Chinese export volumes in Q1 2025 fell to ~111,000 t versus a three-year average of 785,000 t for the same period.
On 9 December 2025, China's Ministry of Commerce (MOFCOM) and General Administration of Customs jointly issued Announcement No. 79 of 2025, reinstating an export-licence management system for ~300 HS-coded steel products effective 1 January 2026. Exporters must obtain a per-contract licence supported by a manufacturer-issued product quality inspection certificate; licences are issued by MOFCOM (for centrally-administered SOEs) and provincial / sub-provincial commerce departments. The regime is the first reinstatement of Chinese steel-export licensing in 16 years (since 2009) and applies the export-licensing instrument — previously used for critical minerals and dual-use goods — to a non-critical bulk commodity for the first time.
The Bureau of Industry and Security (BIS) issued a final rule suspending, for one year, the interim final rule "Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities" (90 FR 47201, Sept. 30, 2025). Effective November 10, 2025 and ending November 9, 2026, the amendments to 15 CFR parts 732, 734, 736, 744, and 748 made by the Affiliates Rule are stayed; the original Entity List restrictions on named parties remain in force, but the automatic 50%-ownership-based extension to unlisted affiliates is paused. Phase two — re-instating the Affiliates Rule changes — is scheduled for November 10, 2026 absent a future extension.
The Bureau of Industry and Security (BIS) issued a final rule (FR Doc. 2025-19858; 90 FR 50858) removing Arrow China Electronics Trading Co., Ltd. from the Entity List under the destination of China and removing six aliases associated with Arrow Electronics (Hong Kong) Co., Ltd. (which itself remains listed but with a narrower alias footprint). The End-User Review Committee (ERC) made the decision by unanimous vote on the basis of information received pursuant to 15 CFR §744.16 regarding the relationships of the aliases and the parties' commitments to enhance export-compliance measures. Effective November 10, 2025.
On 10 November 2025, China's Ministry of Commerce and four other departments issued Announcement No. 73 of 2025, adjusting the "Catalogue of Precursor Chemicals for Export to Specific Countries (Regions)" and adding the United States, Canada and Mexico to the "Specific Countries (Regions) Directory" under the Interim Provisions on the Management of Exports of Precursor Chemicals to Specific Countries (Regions). Exporters must now apply for a license before shipping 13 newly listed categories of precursor chemicals (used in illicit fentanyl and other synthetic-drug manufacture) to these three countries; exports of the same chemicals to other destinations remain unrestricted. The measure took effect the same day it was announced.
China's Ministry of Commerce (MOFCOM) and General Administration of Customs (GAC) issued Announcement No. 72 (2025) on November 9, 2025, suspending Article 2 of Announcement No. 46 (2024) — the provision that had imposed a categorical export ban on gallium, germanium, antimony, superhard materials, and graphite dual-use items destined for the United States. The suspension is valid until November 27, 2026, reverting these exports to China's standard dual-use licensing framework for that period. Article 1 of Announcement No. 46 — prohibiting re-exports to US military end-users regardless of routing — remains fully in force. The measure followed bilateral US-China trade consultations and signals a conditional de-escalation window within China's established critical-minerals counter-strike posture.
China's Ministry of Commerce (MOFCOM) and General Administration of Customs (GAC) issued Announcement No. 70 (2025) on November 7, 2025, suspending for one year the package of rare-earth export-control measures announced on October 9, 2025 (Announcements Nos. 55, 56, 57, 58, 61, 62). The suspended measures include the licensing regime on medium- and heavy-rare-earth elements, rare-earth processing equipment and technologies, lithium-battery and synthetic-graphite anode materials, superhard materials, and — most significantly — the extraterritorial "0.1% content" rule of Announcement No. 61 that asserted licence jurisdiction over foreign-made products containing Chinese-origin controlled rare earths. The gazette text fixes the window explicitly: "自即日起至2026年11月10日" (from the date of issue until November 10, 2026). This is the rare-earth leg of the post-Busan US-China truce; the dual-use leg (gallium, germanium, antimony, graphite) was suspended two days later by the separate Announcement No. 72 (2025), which runs to November 27, 2026. The two instruments create a two-step expiry cliff in November 2026.
MOFCOM Announcement No. 68 of 2025 (商务部公告2025年第68号), issued on 26 October 2025, sets the application requirements and procedures for state-owned trading enterprises (STEs) authorised to export tungsten, antimony and silver during the 2026-2027 cycle. The notice formalises a quota review and joint-approval gate operated through the Key Export Supervision Catalog under MOFCOM's foreign-trade STE authority — distinct from the Export Control Law dual-use regime used in Announcement No. 10 of February 2025. Silver is added for the first time to the STE-managed list, framed by MOFCOM as defence of strategic supply for defence, electronics and photovoltaics. Approved-exporter lists were published in a follow-on review-results notice; the new regime applies to export shipments dated 1 January 2026 onwards.
China's Ministry of Commerce (MOFCOM) and General Administration of Customs (GAC) jointly issued Announcement No. 58 of 2025 on 9 October 2025, adding high-energy-density lithium-ion batteries (cells and packs, >=300 Wh/kg), artificial graphite anode materials, related production equipment, and key manufacturing technologies to the dual-use export control list under licence requirement. The controls were scheduled to take effect 8 November 2025 but were suspended the day before via Announcement No. 70 (2025), which deferred entry-into-force until 10 November 2026 in the context of the US-China Busan economic-trade arrangement. Controls remain legislatively adopted and will become operative unless the suspension is renewed or withdrawn.
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.
The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 29 entries — 26 entities and 3 addresses — to the Entity List under the destinations of China (19), Turkey (9), and the United Arab Emirates (1). BIS determined these parties were diverting US-origin items to Iran, including to parties already on the BIS Entity List and on OFAC's Specially Designated Nationals (SDN) List, in support of Iranian drone-parts and electronics-procurement networks. The rule is a final rule effective October 8, 2025; new license requirements apply to all items subject to the EAR for these listed parties under a presumption-of-denial review policy.
Singapore issued a package of four companion instruments in 2025 to modernise its strategic-goods control architecture: (i) the Strategic Goods (Control) Order 2025 (SGCO 2025), which revokes and replaces SGCO 2024 (S 641/2024) and expands the Singapore Strategic Goods Control List to align with the 2024 Wassenaar Arrangement Munitions List and 2024 EU List of Dual-Use Items, effective 1 December 2025; (ii) the Strategic Goods (Control) (Brokering) (Amendment) Order 2025 (S 662/2025), published 1 October 2025, updating Singapore's extraterritorial brokering regime for controlled goods; (iii) Singapore Customs Circular 01/2025 of 8 April 2025, amending import/export declaration requirements to mandate disclosure of the final destination country of goods rather than the consignee address on the commercial invoice; and (iv) a 4 April 2025 joint MTI–Singapore Customs advisory explicitly warning Singapore-based businesses and intermediaries that their compliance obligations extend beyond Singapore's own controls — i.e., that Singapore authorities will not condone deliberate circumvention or violation of US, EU, or Japanese export controls by Singapore-domiciled intermediaries. This package constitutes the first Singapore export-control-architecture filing in the IPTM register and is directly framed by the February 2025 Singapore–NVIDIA–Inspur–DeepSeek GPU-diversion case in which three Singapore residents were charged for fraudulent re-export of restricted AI accelerators to PRC end-users.
Japan's Ministry of Economy, Trade and Industry (METI) revised its Foreign End-User List (外国ユーザーリスト) — the reference list of foreign organisations for which WMD/missile or, for the first time, conventional-weapons development concerns cannot be excluded, used to trigger catch-all export-licence requirements. The revision adds 92 entities (from China, Hong Kong, North Korea, Russia, Pakistan, Iran and the UAE) and removes 5 entities (from China, Iran and India), taking the list to 835 entities across 15 countries and regions — a net increase of 87. The revised list applies from 9 October 2025, the same date Japan's broader catch-all conventional-weapons supplementary export-control review took effect.
China's Ministry of Commerce, Ministry of Industry and Information Technology, General Administration of Customs, and State Administration for Market Regulation jointly issued Announcement No. 54 of 2025 on 26 September 2025, imposing export licence management on pure electric passenger vehicles (HS 8703801090, motor vehicles equipped solely with an electric drive motor and bearing a VIN), effective 1 January 2026. Only vehicle manufacturers and their authorised distributors may apply, and only for their own-brand output; eligibility criteria require Category I exporters to maintain more than 50 overseas after-sales service and maintenance outlets, a minimum 20% spare-parts inventory rate, and a maximum 48-hour maintenance response time in major export markets. The measure is framed by Beijing as shifting the NEV export sector "from scale expansion to quality first" and curbing non-compliant, low-accountability export practices.
China's Ministry of Commerce issued Announcement No. 51 of 2025 on 25 September 2025, adding three US entities — Huntington Ingalls Industries, Inc. (NYSE: HII, the largest US military shipbuilder), Planate Management Group, and Global Dimensions LLC — to China's Export Control List (出口管制 管控名单), effective the same day. The listing prohibits Chinese exporters from supplying dual-use items to the three firms and requires any ongoing related export activity to cease immediately. MOFCOM cited the firms' "military-technical cooperation with China's Taiwan region" as the trigger, issued in parallel with a same-day Unreliable Entity List designation of three other US firms (Saronic Technologies, Aerkomm, Oceaneering International).
The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 32 entities to the Entity List, with the largest bloc — 23 entries — under the destination of China, plus India (1), Iran (1), Singapore (1), Taiwan (1), Turkey (3), and the United Arab Emirates (2). The rule also removed two addresses from one Russian entry (Intertech Rus LLC) and made 27 typographical corrections to existing entries. Several Chinese additions — including Shanghai Fudan Microelectronics, Sino IC Technology, GMC Semiconductor (Wuxi), and Chinese Academy of Sciences units (National Time Service Center; Aerospace Information Research Institute) — were given footnote 4 designations, extending the EAR's foreign-direct-product (FDP) reach to non-US-origin items destined for Russian military end use. Three Turkish entries (Atempo, EB Teknoloji, Dentun Elektronik) and one Indian entry (AR Sales Pvt Ltd) were footnote-3 Russian Procurement Entity designations. The rule is a final rule effective September 12, 2025; all listed parties are subject to a license requirement for all items subject to the EAR with a presumption-of-denial review policy.
Commission Delegated Regulation (EU) 2025/2003, adopted by the European Commission on 8 September 2025, published in the Official Journal on 14 November 2025 and entering into force on 15 November 2025, amends Annex I of Regulation (EU) 2021/821 to implement the 2024 multilateral decisions of the Wassenaar Arrangement, MTCR, Australia Group, and NSG. The most extensive EU semiconductor-equipment additions since the 2021 framework took effect: ALD, epitaxial deposition, lithography, EUV pellicles/masks/reticles, SEM, and etching equipment, plus tighter controls on quantum computers, advanced FPGAs/ICs for AI training, additive-manufacturing, and cryogenic/superconducting components. The regulation is the EU-side update layer of the Western dual-use export control architecture, structurally aligned with the US BIS advanced- computing/SME packages and the Netherlands DUV-licensing regime.
The 22nd Regulation Amending the Foreign Trade and Payments Ordinance (Zweiundzwanzigste Verordnung zur Änderung der Außenwirtschaftsverordnung), promulgated in Bundesgesetzblatt I 2025 Nr. 261 and entering into force on 1 November 2025, updates Germany's national export-control list (Ausfuhrliste, Annex AL to the AWV) to align with the 2024-cycle decisions of the Wassenaar Arrangement, MTCR, Australia Group, and NSG. It is the German national implementation layer that parallels Commission Delegated Regulation (EU) 2025/2003 — both ingest the same multilateral consensus into the EU+DE dual-use perimeter covering ALD, epitaxial deposition, lithography (EUV pellicles/masks/reticles), SEM and etching equipment, quantum computers, cryogenic components, advanced FPGAs/ICs for AI training, and additive-manufacturing systems. Sets the export-list baseline against which BAFA licence determinations from November 2025 onward are made. Distinct from the parallel AWG Implementing Act (entered into force 2026-02-06) which transposed EU Directive 2024/1226 into German sanctions criminal law.
The US Bureau of Industry and Security (BIS) amended the Export Administration Regulations to remove three foreign-owned semiconductor fabs operating in China — Intel Semiconductor (Dalian) Ltd, Samsung China Semiconductor Co. Ltd, and SK hynix Semiconductor (China) Ltd — from the Validated End-User (VEU) Authorizations list (15 CFR Part 748). BIS framed the VEU program as a "loophole" that previously allowed these fabs to receive most US-origin chipmaking equipment, software and technology license-free, a privilege no US-owned fab in China ever had. After the effective date, every restricted shipment to these fabs will require an individual export license, reviewed case-by-case under the existing 2022/2023 advanced- computing controls. The rule is published as Federal Register document 2025-16735 (90 FR 42321), Docket BIS-2025-0555, RIN 0694-AK32.
China's Ministry of Commerce (MOFCOM) and Ministry of Science and Technology (MOST) jointly issued Announcement No. 28 of 2025 on 15 July 2025, partially adjusting the "Catalogue of Technologies Prohibited or Restricted from Export" first published under Announcement No. 57 of 2023. The revision adds new restricted-export entries covering LFP/LMFP cathode electrode material preparation technology, lithium carbonate/lithium hydroxide preparation technology, and gallium processing technology, extending Beijing's export-control perimeter from raw critical minerals into upstream battery-material process technology. The same revision removed three unrelated entries (traditional Chinese architectural technology and building environment-control technology) from the prohibited/restricted lists. The catalogue took effect immediately upon publication and followed a January 2025 public-consultation draft.
Malaysia's Ministry of Investment, Trade and Industry, acting through the Strategic Trade Controller, issued Directive No. 1/2025 on 14 July 2025 invoking Section 12 of the Strategic Trade Act 2010 to declare high-performance US-origin AI chips (GPUs, TPUs, neural processors, AI accelerators meeting the Annex I total-processing-performance and performance-density thresholds) as "unlisted controlled items". With effect from 14 July 2025, any export, transshipment, or transit of those chips through Malaysian territory requires a Strategic Trade Permit, a 30-day prior notification, an export-control classification from the manufacturer, and a re-export licence from the originating country. The directive is the formal Malaysian response to US scrutiny over alleged Nvidia AI-chip flows to China via Malaysian freight forwarders and data-centre operators, and it remains binding even after the US relaxes its own export rules.
China's Ministry of Commerce issued Announcement No. 35 of 2025 on 9 July 2025, adding 8 Taiwan-based entities to its Dual-Use Items Export Control List under the Export Control Law and the Regulations on Export Control of Dual-Use Items. The listed firms — spanning aerospace/aviation, unmanned systems, and shipbuilding — are barred from receiving dual-use item exports from China; ongoing export activity to them must cease immediately, with exceptions only via case-by-case MOFCOM approval. The measure took effect the same day it was published.
South African Cabinet on 25 June 2025 approved a three-part package to revitalise the domestic ferrochrome sector: (i) placement of chrome ore under export control via the International Trade Administration Commission (ITAC) under the International Trade Administration Act 71 of 2002, requiring an export permit prior to dispatch; (ii) initiation of work on a chrome ore export tax (rate not finalised; market reporting cites 25%); (iii) expanded SEZ incentives for ferrochrome smelters and a negotiated electricity- tariff relief mechanism. The DTIC notice formally placing chrome ore under export control was published in Government Gazette No. 53477 General Notice 6712 on 3 October 2025 with a 30-day public-comment window closing 31 October 2025; the final permit regime takes effect upon subsequent ministerial gazette notice. South Africa accounts for >70% of seaborne chrome ore exports, so the regime is globally material to stainless-steel supply chains.
Taiwan's Ministry of Economic Affairs International Trade Administration (MOEA-ITA) amended the Strategic High-Tech Commodities (SHTC) export-control Entity List on 10 June 2025 (announced 15 June 2025) under Article 13 of the Trade Act, adding 601 new entities — including Huawei Technologies Co. Ltd. and Semiconductor Manufacturing International Corp. (SMIC) plus 599 additional entities domiciled in China, Russia, Iran, Pakistan and Myanmar. Taiwanese exporters (TSMC, UMC, ASE, KYEC and downstream suppliers) must obtain pre-export government licences for direct or third-party shipments of any SHTC-listed item to the listed entities; the action expands Taiwan's total entity-list population to ~10,844 entities. Two follow-on amendments tightened the regime further: a +279-entity expansion on 18 September 2025 and an 18-item commodity-list expansion on 18 November 2025 covering advanced 3D printers, semiconductor manufacturing equipment, electron microscopes and quantum-computing hardware.
The Gabonese Council of Ministers on 30 May 2025 adopted a decision prohibiting all exports of raw (crude) manganese ore effective 1 January 2029, requiring that all manganese mined in Gabon be processed domestically before export. A Commission has been established to draft the implementing regulation, and the Ministry of Industry and Local Transformation is working with COMILOG (Eramet) on transition modalities including the planned Moanda ferromanganese plant (300 kt/yr capacity). The measure applies to the world's #2 manganese producer (~25% of global reserves; ~8 Mt/yr current output, the bulk via COMILOG-Eramet), forcing upstream beneficiation onto Eramet/COMILOG, CITIC, and Ningbo Steel. The ban is the flagship industrial-policy instrument of the "Gabon Industriel 2035" national strategy under President Brice Clotaire Oligui Nguema.
On 23 May 2025 the Bureau of Industry and Security notified major electronic design automation (EDA) suppliers — Cadence Design Systems, Synopsys, and Siemens EDA — by letter that a license is now required for any export, re-export, or in-country transfer of EDA software and technology classified under ECCNs 3D991 and 3E991 where a party to the transaction is located in China or is a Chinese "military end user" wherever located. BIS determined the shipments posed an unacceptable risk of diversion to Chinese military end use. The action was not published as a Federal Register rule; it surfaced publicly only through the affected companies' SEC 8-K disclosures. Synopsys suspended its FY2025 financial guidance in response. BIS rescinded the requirement effective 2 July 2025 (see amendments) amid the broader US-China trade truce, and the three vendors restored access for affected customers.
On 13 May 2025, two days before the AI Diffusion Rule's primary 15 May 2025 compliance date, the Trump administration's BIS announced it would rescind the Biden-era Framework for AI Diffusion (90 FR 4544) and simultaneously issued three guidance documents that re-routed US AI export policy through existing EAR authorities. The package comprises (1) GP10 guidance asserting that all ECCN 3A090 ICs designed by PRC-headquartered firms are presumptively EAR-violative, with Huawei Ascend 910B/910C/910D processors named explicitly — making US- and non-US-person use, transfer, financing, or servicing of those chips anywhere in the world a presumptive General Prohibition 10 violation; (2) a policy statement warning industry that supplying US advanced computing ICs for training or inference of Chinese AI models risks EAR enforcement; and (3) industry guidance on diversion-prevention diligence. BIS stated a formal Federal Register rescission and replacement rule would follow.
The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 18 persons to the Unverified List (UVL) and removing 5. Of the 18 additions, 5 are under China, 6 under Finland, 3 under Türkiye, 2 under Kazakhstan, 1 under Italy, and 1 under the United Kingdom — a geographic distribution dominated by Russia-adjacent diversion corridors. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends use of EAR license exceptions for shipments to listed parties and requires US exporters to obtain a UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 25 April 2025 (90 FR 17339).
Japan's Ministry of Economy, Trade and Industry (METI) overhauled the catch-all export-control framework under the Foreign Exchange and Foreign Trade Act (FEFTA) — the first comprehensive review of Japan's catch-all controls in 12 years (since 2013). Cabinet decisions were taken on 25 March 2025 and 4 April 2025 with METI's consolidated announcement on 9 April 2025; the amended Cabinet Order entered into force on 9 October 2025. The reform (i) splits catch-all-controlled items into "core items" (high dual-use risk, including certain semiconductors and machine tools) and a general catch-all tier, (ii) adds a new end-user requirement alongside the existing end-use requirement and extends both from UN-arms-embargo countries only to "general countries" (everywhere outside Group A), materially expanding the perimeter of items requiring METI export licences for general-country end-users including China, and (iii) introduces an "informed" condition for exports to Group A countries — once METI notifies an exporter of a defined risk pattern, a Group A export becomes licence-required, addressing transit-export-circumvention to Russia. Structurally distinct from the 23-category equipment-specific 2023 amendment (2023-03-31-japan-meti-semi-equipment-export-controls); this is the underlying horizontal catch-all reform and brings Japan's framework closer to US BIS EAR catch-all controls.
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 US Bureau of Industry and Security amended the Export Administration Regulations to add 12 entities to the Entity List under the destinations of China (11) and Taiwan (1) via Final Rule 2025-05427 (90 FR 14046), companion to the larger 70-entity rule (2025-05426) published the same day. Targets fall in three clusters: (i) Beijing Academy of Artificial Intelligence and Beijing Innovation Wisdom Technology — added for acquiring US-origin items in support of China's military modernization, specifically developing large AI models and advanced computing chips for defense; (ii) the Inspur group — Inspur (Beijing) Electronic Information Industry, Inspur Electronic Information Industry, Inspur Electronic Information (Hong Kong), Inspur (HK) Electronics, Inspur Software, and Inspur Taiwan — added as subsidiaries contributing to supercomputers for military end use; and (iii) Henan Dingxin, Nettrix Information Industry, Suma Technology, and Suma-USI Electronics — added for involvement in the development of Chinese exascale supercomputers. License requirements are for all items subject to the EAR; review policy is presumption of denial for the AI cluster and policy of denial for the supercomputer clusters.
In its first major export-regulatory action of the second Trump administration, BIS amended the EAR to add 70 entities to the Entity List under the destinations of China (42), Iran (2), Pakistan (19), South Africa (3), and the United Arab Emirates (4), and modified four existing entries (France, Iran, Senegal, UK). New listings carry a license requirement for all items subject to the EAR with a presumption-of-denial review policy and no license exceptions available. Stated objectives include restricting China's acquisition of high-performance computing and quantum technologies for military use, impeding hypersonic-weapons development, disrupting Iran's UAV and defense procurement, and impairing Pakistan's unsafeguarded nuclear and ballistic-missile programs. The rule also targets the Test Flying Academy of South Africa for using U.S.-origin items to train Chinese military pilots.
BIS published a correcting amendment to its January 16, 2025 interim final rule "Implementation of Additional Due Diligence Measures for Advanced Computing Integrated Circuits" (FR Doc 2025-00711). The correction revises the license-requirement table for ECCN 3A090 by changing the first row, first column from "RS applies to the entire entry, except 3A090.a" to "RS applies to 3A090.a", aligning the Regional Stability control scope with BIS's intended policy in the Advanced Computing Chip rules. Effective February 11, 2025; comments due March 14, 2025. Docket BIS-2024-0055; RIN 0694-AJ98.
MOFCOM and the General Administration of Customs jointly issued Announcement No. 10 [2025] on 4 February 2025, imposing dual-use export-licence controls on items related to tungsten, tellurium, bismuth, molybdenum and indium under the Export Control Law and Dual-Use Items Export Control Regulations. The controls cover metals, alloys, powders, compounds and related processing technologies across roughly 25 listed item categories (41 HS 10-digit codes). The measure is global in scope but was issued the same day China announced 10-15% retaliatory tariffs on US LNG, coal, crude and farm equipment in response to the Trump administration's 10% fentanyl-tariff hike — extending the MOFCOM critical-minerals control regime beyond gallium/germanium/graphite/antimony/heavy-REEs.
Japan's Ministry of Economy, Trade and Industry (METI) revised its Foreign End-User List, the reference list of foreign organisations for which concern cannot be eliminated regarding involvement in the development of weapons of mass destruction and missiles, used to support catch-all export-licence requirements. The revision added 42 entities, taking the list to 748 entities from 15 countries and regions, and applies from 5 February 2025.
BIS published an interim final rule (FR Doc 2025-00711, 90 FR 4544-publication slot; companion to the AI Diffusion Framework signed three days earlier) revising the EAR to add explicit due-diligence procedures for advanced computing integrated circuits captured by ECCN 3A090. The rule (i) creates an Authorized IC Designer / Approved IC Packager regime so that foundries and OSATs can identify trustworthy customers via lists maintained by BIS, (ii) imposes new front-end-fabricator reporting requirements for any 3A090.a IC produced for an authorized IC designer to give the US government supply-chain visibility, and (iii) adjusts the scope of covered advanced-computing items. Effective 16 January 2025; compliance required from 31 January 2025; comment period extended to 14 March 2025. The rule was immediately followed by the 16 January Entity List additions (Sophgo et al.) targeting circumvention paths and was technically amended on 14 February 2025 to narrow the RS license requirement to ECCN 3A090.a only.