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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 2 May 2026, MOFCOM issued Announcement No. 21 of 2026 — the first concrete prohibition order ever issued under China's 2021 "Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures" (Blocking Rules) and the Anti-Foreign Sanctions Law (AFSL). The order prohibits any Chinese organisation, individual, or foreign party operating in China from recognising, enforcing, or complying with US sanctions imposed under Executive Orders 13902 and 13846 against five Chinese independent ("teapot") refineries — Hengli Petrochemical (Dalian) Refining Co., Ltd., Shandong Shouguang Luqing Petrochemical Co., Ltd., Shandong Jincheng Petrochemical Group Co., Ltd., Hebei Xinhai Chemical Group Co., Ltd., and Shandong Shengxing Chemical Co., Ltd. — all designated by OFAC for purchasing Iranian crude. The announcement is the first operational test of the framework built up across the AFSL (2021), the AFSL Implementation Regulations (Order 803, March 2025), and State Council Order 835 on Countering Foreign Unlawful Extraterritorial Jurisdiction (April 2026), and creates a direct compliance conflict for banks, insurers, traders, and shipping companies operating in or with China that had been winding down their exposure to the listed refineries.

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).

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.

China's Ministry of Transport (Water Transport Bureau, document 交办水〔2025〕59号), acting under the PRC International Maritime Transport Regulations, issued a measure on 10 October 2025 imposing escalating special port service fees on U.S.-linked vessels calling at Chinese ports from 14 October 2025. Fees apply at the first Chinese port of call per voyage to (i) U.S.-owned, (ii) U.S.-operated, (iii) ≥25% U.S.-equity, (iv) U.S.-flagged, or (v) U.S.-built vessels, charged per net ton on a stepped schedule (¥400/NT from 14 Oct 2025, ¥640/NT from 17 Apr 2026, ¥880/NT from 17 Apr 2027, ¥1,120/NT from 17 Apr 2028) and capped at five voyages per vessel per year. The measure is the first MOT-issued trade-remedy instrument in the IPTM register and the direct, named-target mirror response to USTR's 17 April 2025 Section 301 maritime Notice of Action. Both regimes were mutually suspended for one year from 10 November 2025 through 9 November 2026 following the 30 October 2025 Trump-Xi Busan meeting.

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 Unreliable Entity List Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 10 on 9 October 2025 designating 14 foreign entities — Dedrone by Axon Inc., DZYNE Technologies Incorporated, Elbit Systems of America LLC, Epirus Inc., AeroVironment Inc., Exelis Inc., Alliant Techsystems Operations LLC, BAE Systems Inc., Teledyne FLIR LLC, VSE Corporation, Cubic Global Defense, Recorded Future Inc., the Halifax International Security Forum, and TechInsights Inc. (with nine named subsidiaries) — for engaging in military-technical cooperation with Taiwan, harmful statements concerning China, and assisting foreign governments in suppressing Chinese enterprises. The measures (i) prohibit the listed entities from China-related import-export activity, (ii) ban new investment in Chinese territory, and (iii) for the first time under the UEL framework explicitly prohibit Chinese organisations and individuals from transmitting data or providing sensitive information to the listed entities. Issued the same day as MOFCOM/GAC Announcements No. 61/62 extending rare-earth export controls extraterritorially under a 0.1% de minimis content rule, the package marks the first UEL deployment targeting counter-drone original equipment manufacturers and the first to introduce a data-transmission restriction.

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).

China's MOFCOM Unreliable Entity List Working Mechanism designated three US firms — Saronic Technologies, Aerkomm Inc., and Oceaneering International — on 25 September 2025, effective the same day, under Article 2 of the Provisions on the Unreliable Entity List (MOFCOM Order No. 4 of 2020) and citing the Foreign Trade Law, the National Security Law, and the Anti-Foreign Sanctions Law. MOFCOM's stated trigger is the firms' "so-called military-technical collaboration with China's Taiwan region." Measures bar the designees from China-related import/export activity and new investment in mainland China, with entry/work-permit restrictions on relevant management personnel.

MOFCOM Announcement No. 25 of 2025 (18 May 2025) issued the final ruling in the anti-dumping investigation into copolyacetal (共聚聚甲醛, polyoxymethylene copolymer/POM copolymer, an engineering plastic used in automotive parts, electronics and precision components) imported from the United States, the EU, Taiwan and Japan, initiated 19 May 2024 (MOFCOM Announcement No. 18 of 2024). MOFCOM found dumping, material injury to the domestic industry and a causal link, and imposed anti-dumping duties effective 19 May 2025 for a five-year term under Article 38 of China's Anti-Dumping Regulations. Rates: 74.9% for US companies; 42.0% for EU companies; 3.8%-32.6% for Taiwan-region companies (named companies at the low end, "other Taiwan companies" at 32.6%); 33.9%-43.7% for Japanese companies (named companies at the low end, "other Japanese companies" at 35.5% per the 2026 succession notice). On 20 August 2026, MOFCOM Announcement No. 36 of 2026 ruled that Daicel Corporation succeeds to Polyplastics Co., Ltd.'s 35.5% rate and Daicel HPP Taiwan Co., Ltd. succeeds to Polyplastics Taiwan Co.'s 3.8% rate, both following corporate reorganizations, effective 21 August 2026 (filed below as an amendment).

China's MOFCOM Unreliable Entity List Working Mechanism designated six US firms on 9 April 2025, effective 12:01 Beijing time 10 April 2025, under MOFCOM Order No. 4 of 2020. Cited trigger: participation in arms sales to Taiwan or military-technology cooperation with Taiwan in disregard of China's stated opposition, "seriously harming China's national sovereignty, security and development interests." Measures prohibit the six entities from import/export activities related to China, new investments in China, and impose entry/work-permit restrictions on senior management.

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.

China's MOFCOM Unreliable Entity List Working Mechanism designated 11 US drone-sector companies on 4 April 2025 — Skydio Inc., BRINC Drones Inc., Kratos Unmanned Aerial Systems Inc., Insitu Inc., Red Six Solutions LLC, SYNEXXUS Inc., Firestorm Labs Inc., HavocAI, Neros Technologies, Domo Tactical Communications LLC, and Rapid Flight LLC — citing military-technology cooperation with Taiwan in violation of China's One-China principle. Designations prohibit the 11 firms from import/export activity related to China, bar new investments in China, and restrict senior-executive entry. Issued on the same date as the MOFCOM heavy rare-earth export-licensing measure, the designations formed a paired retaliation package responding to the 2 April 2025 US "Liberation Day" reciprocal-tariff escalation. On 15 May 2025 MOFCOM suspended the UEL restrictions on all 11 companies for 90 days in line with the US-China Geneva tariff truce.

China's Unreliable Entity List (UEL) Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 2 on 4 February 2025, designating PVH Group (parent of Calvin Klein and Tommy Hilfiger) and Illumina Inc. (US genomics / gene-sequencing equipment maker) as Unreliable Entities under the 2020 UEL Provisions, citing violations of normal market-transaction principles and discriminatory measures against Chinese enterprises. PVH was cited for its Xinjiang-cotton sourcing boycott (MOFCOM probe launched September 2024); Illumina was cited for restricting Chinese customers' access to gene-sequencing equipment. The announcement was issued on the same day as China's IEEPA-retaliation tariff package (10–15 % on US coal, LNG, crude oil, agricultural goods, and autos), making it the first UEL listing of a Western consumer-brand / retail company and the first combining a UEL designation with a subsequent sector-specific export prohibition (gene sequencers, imposed 28 February 2025).

China's Unreliable Entity List Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 1 on 2 January 2025 designating 10 US defense entities — five Lockheed Martin subsidiaries (Missiles and Fire Control, Aeronautics, Missile System Integration Lab, Advanced Technology Laboratories, Ventures), the Javelin Joint Venture (Raytheon/Lockheed Martin), Raytheon Missile Systems, and three General Dynamics units (Ordnance and Tactical Systems, Information Technology, Mission Systems) — as Unreliable Entities under the 19 September 2020 Provisions on the Unreliable Entity List, citing their participation in US arms sales to Taiwan. The measures prohibit the 10 firms from engaging in import/export activity related to China and from making new investments in China, and bar approval/renewal of work permits and stay/residence qualifications for their senior executives. This is the first multi-entity UEL designation under the 2020 Provisions and was issued the same day as the parallel MOFCOM Announcement [2025] No. 1 of the export-control bureau adding 28 US entities to China's Export Control List — together establishing a coordinated two-track countermeasure template against US defense and dual-use industry.

China's Ministry of Commerce announced on 3 December 2024 (MOFCOM Announcement No. 46 of 2024) a formal ban on dual-use exports to the United States of gallium, germanium, antimony and superhard materials including diamond and cubic boron nitride. The measure also imposed strict end-use review on graphite exports to the US, with extra scrutiny of military end-uses. It came one day after BIS issued a major export- control package on 2 December 2024 expanding controls on Chinese semiconductor equipment and adding 140 entities to the Entity List, and was framed by MOFCOM as a national- security countermeasure.