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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.
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.
BIS published a final rule removing the UAE from Export Administration Regulations Country Groups D:3 and D:4 and adding it to Country Group A:5 — the tier reserved for the closest US allies. The change unlocks License Exception STA (military items, commercial satellites/spacecraft, and dual-use goods for oil/gas, desalination and civil nuclear power) plus several other license exceptions, and grants the UAE government and BIS-preapproved entities (currently G42 and Core42 only, per Supplement No. 8) license-free export of advanced computing items. Preapproved private entities have a 270-day window to become majority US-owned or lose automatic eligibility; other private UAE entities must still petition BIS case-by-case.
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. 26 of 2026 on June 24, 2026, establishing a formal reporting and handling system for violations of export controls on strategic minerals and dual-use items, effective July 1, 2026. The mechanism opens two reporting channels — a dedicated hotline (010-12369) and an online portal (aqygzj.mofcom.gov.cn) — through which any organisation or individual may report suspected violations including unauthorised exports, circumvention via third-country re-routing, illegal technology transfers, and provision of services to sanctioned exporters. Anonymous reports are accepted; real-name reporters may qualify for monetary rewards; voluntary self-disclosure is treated as a mitigating factor in penalty determination. Service providers including freight forwarders and financial institutions face mandatory reporting obligations when they discover suspected violations in the course of business.
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.
Japan's Diet passed the Foreign Exchange and Foreign Trade Act (FEFTA) 2026 Amendment on 29 May 2026; the law was promulgated on 5 June 2026. The amendment represents the most significant overhaul of Japan's inbound FDI screening regime since FEFTA was first applied to national-security transactions in 2019. Three structural additions: (1) indirect-acquisition screening — extends mandatory prior-notification to acquisitions of Japanese sensitive-sector companies effected through intermediate holding structures or offshore parent vehicles, closing the principal gap exploited by Chinese and GCC SWF investors via SPV chains; (2) call-in powers — grants the Minister of Finance authority to open a review up to ten years retroactively where an acquisition was not pre-notified or where circumstances have materially changed since clearance, directly analogous to CFIUS § 721(b)(1)(D) retroactive jurisdiction; (3) cross-ministerial "Japan CFIUS" consultation framework — formally institutionalises a standing inter-agency committee (Finance, METI, MoD, NPA, MIAC) modelled on the US CFIUS committee, replacing the prior ad-hoc inter-ministerial process. Cross-ministerial and indirect-acquisition provisions entered into force immediately on promulgation (5 June 2026); remaining Cabinet-Order-level implementing provisions to follow within one year.
On 23 April 2026, the Council of the European Union adopted the 20th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2026/506 amending Regulation 833/2014 (sectoral sanctions) and Council Regulation (EU) 2026/511 amending Regulation 269/2014 (asset-freeze listings — 120 additional individuals and entities, the largest single tranche in two years). The package operationalises and extends the crypto-sanctions architecture introduced in the 19th package and constructs the legal scaffolding for a future full prohibition on maritime services to vessels carrying Russian crude/petroleum products. Headline measures: (i) full sectoral prohibition on transactions with crypto-asset service providers and exchange platforms established in Russia or Belarus, plus designation of the rouble-backed stablecoin RUBx and the digital rouble (CBDC) on Annex LIII — effective 24 May 2026, with EU support for the digital rouble's development banned outright; (ii) 36 new energy-sector listings spanning upstream extraction, refining and transportation; (iii) prohibition on providing technical, financial, brokering and insurance services to Russia-flagged, Russian-certified or Russian-managed LNG tankers and icebreakers effective 25 April 2026, extending to foreign-flagged vessels operating in Russian interests by January 2027 and culminating in a categorical ban on LNG terminal services to Russian-controlled entities on 1 January 2027; (iv) full transaction ban on 20 Russian banks plus four third-country banks listed for SPFS connectivity / sanctions circumvention; (v) 46 newly listed shadow-fleet vessels and new tanker sale-due-diligence obligations on EU shipping operators; (vi) 58 designations of companies and associated individuals in the Russian military-industrial complex including drone developers/manufacturers; (vii) further Annex IV third-country circumvention enabler listings (China, Hong Kong, Turkey, UAE); (viii) parallel measures against Belarus. Entry into force on 24 April 2026 (day following publication in OJ L_202600506), except for measures with explicit deferred application dates.
On 15 April 2026 Japan's Ministry of Economy, Trade and Industry (METI) published the interim summary "Manufacturing Base Strengthening Report" from the Study Group on Strengthening Manufacturing Base in Light of Geopolitical Risks. The report frames Japan's manufacturing base as the source of national power and proposes shifting economic-security support for "autonomy assurance" from "point" measures to "area"-wide measures — expanding the scope of Specified Critical Materials under the 2022 Economic Security Promotion Act (ESPA) beyond narrowly defined inputs to cover foundational petrochemicals (ethylene, propylene, methanol, synthetic rubber) and process-industry technologies (casting, forging), plus components for emerging technologies (humanoid-robot actuators and sensors, lasers for quantum computing). It is the cornerstone framework document operationalising METI's FY2026 strategic-budget package (~¥3.07 trillion overall envelope; ~¥1.23 trillion specifically for semiconductors and AI, including ¥150bn for Rapidus and ¥387.3bn for AI development) as Japan's coordinated response to deepening Chinese export-control pressure on dual-use items, gallium/germanium, graphite, antimony and heavy rare earths.
On 1 April 2026, Prime Minister Takaichi Sanae and President Emmanuel Macron held a Tokyo summit and signed a bilateral roadmap on cooperation in critical minerals — the first formal Japan-France instrument on supply-chain resilience for rare earths and other critical materials. The centrepiece is joint government support for Caremag, a heavy rare-earths refining project in southern France due to begin operations in late 2026, with backing from Japan Organization for Metals and Energy Security (JOGMEC), Iwatani Corporation, and the French government; the project targets approximately 20% of Japan's future demand for dysprosium and terbium (heavy rare-earth oxides used in EV motors, offshore-wind turbines, and electronic components). The two leaders also launched parallel high-level dialogues on dual-use AI, quantum technologies, space (including debris mitigation), cybersecurity, and a joint declaration on startups and innovation, expressing "serious concerns" over export controls on critical minerals and other materials affecting global supply chains — an explicit reference to China's tightening rare-earths export regime.
Turkish President Erdoğan signed Presidential Decision No. 11068 on 16 March 2026, published in the Resmî Gazete on 17 March 2026, establishing a mandatory pre-clearance regime for the transit passage and re-export of controlled military items through Türkiye's customs territory. Covered items include military vehicles and defence equipment, weapons and ammunition and their spare parts, military explosives, and dual-use technologies associated with these categories, as defined under Law No. 5201. Any entity seeking to move such goods through Türkiye must obtain a "uygunluk yazısı" (compliance letter) from the Ministry of Trade, which reviews applications in consultation with relevant public institutions. The measure directly operationalises Türkiye's response to sustained US pressure over Iran-related sanctions evasion via Turkish transit corridors and entity-list additions naming Türkiye-based diversion networks.
On 25 February 2026 the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (Ukraine Ordinance) and the Ordinance on Measures against Belarus, completing implementation of the EU's 19th sanctions package with effect from 26 February 2026. Headline measures: a complete ban on the purchase and import of Russian LNG taking effect 25 April 2026 (transition period until end-2026 for pre-existing long-term contracts); a complete prohibition on the provision of crypto-asset services to Russian persons and companies; new service bans covering advanced-technology / AI / high-performance-computing services and tourism-related services; expansion of the dual-use end-user list (Annex 2) including additional Chinese entities; SECO authority to grant divestment-exemption licences until end-2026 under Art. 30a; and parallel adoption of the EU October 2025 Belarus measures via amendment to the Belarus Ordinance.
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.
NIB, the multilateral development bank owned by the eight Nordic and Baltic member states, signed a EUR 11.4 million 10-year loan with Metrosert AS, Estonia's national testing, calibration and certification body, to finance a new Drone Technology Unit within Metrosert's Applied Research Centre in Tallinn. The unit will house nine laboratories to develop, validate and industrialise unmanned aerial, ground and maritime systems, with most planned activity explicitly defence-related, covering unmanned aviation, communications, navigation, flight physics and hardware security. NIB financing at preferential development-bank rates functions as a below-market state-backed subsidy to a strategic dual-use research facility; the unit is targeted to be fully operational by summer 2027 as part of a EUR 42.9 million total Applied Research Centre build-out.
On 16 January 2026, the US Treasury's Office of Foreign Assets Control designated 21 individuals and entities and identified one vessel for transferring oil products, procuring weapons and dual-use equipment, and providing financial services to Iran-backed Ansarallah (the Houthis). Designated parties — oil-trading and exchange companies, a shipping/logistics facilitator, and front-company operatives — are based in Yemen, Oman, and the UAE, and are accused of running an oil-sales and financial- facilitation network that Treasury says generates the Houthis over $2 billion in annual illicit revenue. The action was taken pursuant to Executive Order 13224 (as amended) and builds on a multi-year cadence of prior OFAC designations against Houthi leaders, smugglers, financiers, and weapons-procurement suppliers.
Malaysia's Minister of Finance gazetted P.U. (A) 25/2026, the Customs (Prohibition of Imports) (Amendment) (No. 2) Order 2026, on 14 January 2026, taking effect 15 January 2026. The order adds ammonium nitrate and potassium nitrate to the list of goods subject to import licensing under the Customs (Prohibition of Imports) Order, requiring importers to obtain an approved permit before bringing either chemical into Malaysia. Both compounds have legitimate fertilizer and industrial uses but are also recognised explosive precursors, and the measure is administered as a dual-use/security-sensitive chemical control rather than a straightforward agricultural-input tariff. Global Trade Alert lists Canada, China and Germany among the trade partners affected by the new licensing gate.
On 12 January 2026 Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annexes 8, 14, 15b and 33 of the Ordinance on Measures in Connection with the Situation in Ukraine, with effect from 23:00 on 13 January 2026. The amendment adds 5 natural persons, 4 organisations (one Vietnam-based, three based in the UAE and Russia), and 41 vessels to the asset-freeze and port-access-prohibition annexes, and makes technical corrections to 7 existing entries. The measure is a routine incremental listing update continuing Switzerland's autonomous alignment with the EU's Russia sanctions regime, following the first EU 19th-package tranche adopted 12 December 2025 ([switzerland-19th-eu-sanctions-package-december-listings](2025-12-12-switzerland-19th-eu-sanctions-package-december-listings.md)) and preceding the substantive package completion of 25 February 2026 ([switzerland-19th-eu-sanctions-package-russia-belarus](2026-02-25-switzerland-19th-eu-sanctions-package-russia-belarus.md)).
On 9 January 2026, Canada's Minister of Industry Mélanie Joly announced Defence Industry Assist (DI Assist), a CAD 244.2 million (~USD 178.6 million) funding and advisory initiative delivered through the National Research Council's Industrial Research Assistance Program (NRC IRAP). The programme funds high-potential Canadian SMEs developing made-in-Canada defence and dual-use technologies, with the stated aims of reducing barriers to market entry, connecting recipients to procurement pathways, and strengthening domestic supply-chain collaboration. It sits within Canada's broader Defence Industrial Strategy (CAD 6.6 billion over five years from 2025-26) and Canada's push toward its 2% NATO defence-spending target.
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.
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 Overseas Investment (National Interest Test and Other Matters) Amendment Act 2025 (No 81 of 2025) is the largest rewrite of New Zealand's Overseas Investment Act 2005 since the 2018 residential-land amendment. The Bill (Government Bill 171) was introduced by the Minister of Finance in June 2025, passed all three readings in the House of Representatives, received Royal Assent on 19 December 2025, and was brought into force on 6 March 2026 by the Overseas Investment (National Interest Test and Other Matters) Amendment Act 2025 Commencement Order 2026 (SL 2026/2). The Act replaces the OIA's residual "investor test" discretion with a single statutory national-interest test applied to all "sensitive asset" transactions, introduces a new s 29B repeat-investor mechanism (Treasury does not re-litigate investor risk factors on subsequent applications outside strategically important businesses), creates new military / dual-use technology call-in transactions and critical-direct-supplier call-in transactions (amended s 85), and adds a no-change-of-control transaction category. Administered by The Treasury (policy lead) and Toitū Te Whenua LINZ (operations / case handling), with consent decisions issued by the responsible Ministers.
On 19 December 2025 the Swiss Federal Assembly adopted in final vote the Federal Act on the Screening of Foreign Investments (Bundesgesetz über die Prüfung ausländischer Investitionen, Investitionsprüfgesetz / IPG; popularly the "Lex China", parliamentary business 22.035). The Act introduces Switzerland's first general ex-ante FDI-screening regime: acquisitions of control over Swiss companies active in security-critical sectors by foreign state-controlled investors require prior approval by SECO, with escalation to the Federal Council. The optional- referendum window runs until 17 April 2026; entry into force is not expected before 2027 once implementing ordinances are adopted. Critical sectors named in the Act include military and dual-use goods, electricity grids and generation, water supply, pharma and health, telecommunications, transport infrastructure and financial-market infrastructure.
The European Investment Bank signed a EUR 100 million multi-beneficiary intermediated loan with Piraeus Bank SA on 18 December 2025 under the "Piraeus Bank L4SMEs Security & Defence" project (EIB ref. 20250612, approved 12 November 2025). At least 50% of the on-lent amount must go to SMEs and mid-caps active in Greece's security and defence sector, addressing constrained access to finance these firms face due to sector-specific sensitivities and dual-use classification. The EIB describes it as its first-ever financing in Greece dedicated to the security and defence sector, part of a wider Pan-EU Security & Defence Lending Envelope; Global Trade Alert separately logged the transaction (reporting the headline amount as EUR 200 million) as a "red"-flagged state-linked lending-support intervention.
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 12 December 2025 the Swiss Federal Council adopted the first tranche of listings aligning with the EU's 19th Russia sanctions package (Council Regulation (EU) 2025/2033, 23 October 2025), amending the Ordinance on Measures in Connection with the Situation in Ukraine and the Belarus Ordinance with effect from 13 December 2025. The decision adds asset freezes and entry/transit bans for 22 natural persons and 42 entities tied to Russia's military-industrial complex, energy sector and shadow-fleet vessel management; extends purchase/sale/insurance bans to over 100 additional tankers; imposes transaction restrictions on 5 Russian banks and 4 Russian-bank branches in Belarus and Kazakhstan for use of specialised financial-messaging services; sanctions Chinese and Hong Kong trading companies and refineries implicated in circumventing the G7 oil price cap; and designates 5 Belarusian persons linked to military-industrial activities. Divestment-exemption deadlines for Swiss persons winding down Russian holdings are extended to end-2026. This is a partial, listings-only tranche — the more substantive measures of the EU's 19th package (Russian LNG import ban, crypto-services prohibition, AI/HPC service bans) were not adopted until the Federal Council's follow-on decision of 25 February 2026.
On 11 December 2025 the Council of the EU presidency, the European Parliament, and the European Commission reached provisional political (trilogue) agreement on the revision of Regulation (EU) 2019/452 establishing a framework for the screening of foreign direct investments into the Union, concluding interinstitutional negotiations on the Commission's proposal of 24 January 2024. The revised regime upgrades the 2019 cooperation-mechanism-only framework into a hybrid harmonised/mandatory regime: all 27 Member States must establish FDI screening mechanisms (replacing the current patchwork in which some Member States have no mechanism at all); mandatory minimum sectoral scope is set EU-wide and covers dual-use items, military equipment, hyper-critical technologies (general-purpose AI with space/defence relevance, quantum technologies, semiconductors), critical raw materials, critical entities in energy/transport/digital infrastructure, electoral infrastructure, and certain financial-system entities; foreign investments routed through EU subsidiaries fall within the perimeter; a shared database prevents Member-State arbitrage; and an optional single electronic-filing portal becomes available if requested by at least nine Member States. Screening decisions remain the exclusive responsibility of the Member State in which the investment is made. Once the Regulation enters into force (after Council and Parliament formal adoption and OJ publication, both pending as of the political-agreement date), the new rules will apply after an 18-month transition period — implementation expected toward the end of 2027.
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.
Russia's Government adopted Resolution N° 1958 on 29 November 2025, amending Resolution N° 313 of 9 March 2022 to add eight commodity positions to Appendix 3 — the list of dual-use goods banned for export to "unfriendly" states. The added items are specialty electro-optical and semiconductor materials: lithium niobate, zinc telluride, gadolinium-gallium garnet, gallium arsenide, gallium phosphide, unprocessed and processed quartz wafers/plates, and polished tellurium-oxide prisms. These materials are inputs to electro-optical components (modulators, acousto-optic devices, IR/laser optics) with both civil and military (guidance, imaging) applications. The measure took effect 1 December 2025 and runs through the underlying ban's 31 December 2027 expiry; it applies to all countries except Eurasian Economic Union member states.
ECOFIN on 12 December 2025 adopted a Council Implementing Decision approving the 4th amendment to Poland's National Recovery and Resilience Plan (Krajowy Plan Odbudowy, KPO), following Commission proposal C(2025) 7998 final of 19 November 2025. The amendment modifies 80 measures within the plan while keeping Poland's total financial contribution under the EU Recovery and Resilience Facility (RRF) unchanged at EUR 25,276,853,716 in grants, alongside an estimated EUR 20.6 bn REPowerEU chapter envelope. Adopted in parallel with amendments for Austria, Cyprus, Czechia, France, Greece, Latvia, Malta, Portugal and Slovenia, this amendment continues the structural pivot — first opened by the May 2025 third amendment — that allows Poland to redirect post-COVID recovery funds toward defence-industrial and dual-use spending given the NATO eastern-flank context.
Israel's Minister of Defense signed an order on 18 November 2025 revoking the Order Governing the Control of Commodities and Services (Engagement in Encryption Items) of 1974, with effect on 21 March 2026 (four-month implementation period). The 51-year-old standalone Encryption Order regime — which licensed both civilian and defense-grade encryption items through a parallel Ministry of Defense track — is replaced by a unified architecture in which defense-grade dual-use items move to the Defense Export Controls Agency (DECA) at the Ministry of Defense, and civilian dual-use items (Wassenaar list) move to the Export Control Agency (ECA) at the Ministry of Economy and Industry. Many B2C consumer products with embedded encryption are decontrolled outright; B2B / commercial products remain controlled but under DECA or ECA rather than the legacy Encryption Order regime.
Taiwan's Ministry of Economic Affairs International Trade Administration (MOEA-ITA) issued a pre-notice (17 November 2025, doc. 經授貿字第 11450120760號) proposing amendments to the "Dual-Use Goods and Technology Export Control List" and the "General Military Goods List" under the Strategic High-Tech Commodities (SHTC) regime, adding or reclassifying items in the basic-inorganic-chemicals, chemical-products, and engines/turbines categories to align with Wassenaar Arrangement list updates. Following the standard 60-day public-comment period, MOEA-ITA published the finalised amendment on 11 February 2026 (doc. 經貿字第 11550200140號), effective immediately, requiring exporters of the newly listed dual-use and military goods to obtain prior export licences regardless of destination.
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.
Japan's Cabinet adopted a Cabinet Order on 11 November 2025 (promulgated 14 November 2025, effective 14 February 2026) amending Appended Table 1 of the Export Trade Control Order (輸出貿易管理令) to add three new list-control item categories: (i) peptide synthesizers and related components (Item group mapping to Australia Group 2023–2024 plenary dual-use biotechnology controls, aligning Japan with the US BIS implementation promulgated December 2024), (ii) powders of refractory metals or their alloys below specified particle-size and purity thresholds — tungsten, molybdenum, niobium, tantalum, and rhenium powders used as additive- manufacturing feedstocks (Item 5(20), implementing a Wassenaar Arrangement plenary outcome on metal-powder dual-use), and (iii) modules, assemblies, or devices incorporating field-programmable logic devices (FPGAs) above specified gate-count and process-node thresholds (Item 7(10-2), extending Japan's semiconductor-component AI-compute perimeter). This is the first discrete Appended Table 1 list-control amendment filed under the post-October-2025 FEFTA catch-all- controls overhaul architecture.
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.
The Hrvatski sabor (Croatian Parliament) unanimously adopted the Act on Screening of Foreign Direct Investments on 24 October 2025; the law was published in Narodne Novine 136/2025 and entered into force on 13 November 2025. It establishes Croatia's first-ever statutory horizontal FDI-screening regime, implementing EU Regulation 2019/452 in Croatian law. The Act captures direct or indirect acquisitions by non-EU investors of at least 10 % of share capital, voting rights or property rights in Croatian entities operating in sensitive sectors (defence, dual-use, critical infrastructure, critical minerals, emerging tech, sensitive personal data, energy, transport, health, digital infrastructure, media, financial services). The reviewing authority must decide within 120 days, exceptionally 150 days, of a complete application. Croatia was one of the last EU Member States without a horizontal screening law.
On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.
On 23 October 2025, the Council of the European Union adopted Council Regulation (EU) 2025/2041 (amending Regulation (EC) No 765/2006) and Council Decision (CFSP) 2025/2040 (amending Decision 2012/642/CFSP), widening the EU's Belarus restrictive-measures regime in lockstep with the 19th Russia sanctions package adopted the same day. The package widens the export ban to industrial goods (salts, ores, rubber articles, tyres, millstones, construction materials, electronic components, rangefinders, propellant chemicals, metals/oxides/alloys), extends the import ban to all acyclic hydrocarbons, introduces a new prior-licensing requirement for services supplied to Belarus, its government, or public bodies, and mirrors the Russia regime's space, AI, and high-performance/ quantum-computing service restrictions. A companion instrument, Council Implementing Regulation (EU) 2025/2039, adds 5 new asset-freeze listings (2 individuals + 3 entities, including JSC Holography Industry, Horizont Holding, and ICT Horizont). Entered into force 24 October 2025.
On 10 October 2025 Vietnam's Government issued Decree No. 259/2025/NĐ-CP, establishing the country's first comprehensive statutory framework for strategic trade control — covering the export, temporary import for re-export, transshipment, transit, and cross-border trade of strategic goods defined as: (a) WMD-related items, (b) conventional weapons, and (c) dual-use goods spanning nuclear, electronics, telecommunications, sensors, aviation, maritime, aerospace, biochemical, metals, and chemical categories. The decree creates a Ministry of Industry and Trade (MoIT) licensing regime with an ICP (Internal Compliance Programme) fast-track for certified exporters of two or more years' standing, and includes catch-all provisions requiring licensing even for unlisted goods where WMD end-use or a designated end-user is suspected. Structurally, the decree represents Vietnam's transition from ad-hoc export-management provisions under legacy Decree 69/2018/NĐ-CP to a unified strategic-trade-control architecture analytically aligned with the Wassenaar Arrangement, Australia Group, Nuclear Suppliers Group, and MTCR control-list architecture. It positions Vietnam as a compliant strategic-goods manufacturing hub within the US-led friend-shoring supply chain, directly preceding the US announcement in February 2026 of Vietnam's removal from EAR Country Groups D:1–D:3.
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.
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.
The US Treasury's Office of Foreign Assets Control designated 21 entities and 17 individuals across three procurement networks supplying Iran's Ministry of Defense and Armed Forces Logistics (MODAFL) and its subordinate weapons producers. The networks sourced ballistic-missile guidance components (accelerometers, gyroscopes, MEMS) for the Shahid Bakeri Industrial Group and Shahid Hemmat Space Group, dual-use radar/missile-guidance electronics routed through Hong Kong and China for Shiraz Electronics Industries, and helicopter parts — including a US-origin helicopter — routed through Germany, Türkiye, Portugal and Uruguay for Iran Helicopter Support and Renewal Company (PANHA). The action is Treasury's first nonproliferation-sanctions tranche following the 27 September 2025 UN Security Council "snapback" reimposing pre-JCPOA sanctions on Iran.
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 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).
India's Directorate General of Foreign Trade (DGFT) issued Notification No. 31/2025-26 on 23 September 2025, revising Appendix-3 of Schedule-II of the ITC(HS) Export Policy to add a new Category 7 — "Certain Emerging Technologies and related items" — to the SCOMET (Special Chemicals, Organisms, Materials, Equipment and Technologies) list. Category 7 brings under export-licence control: quantum-computing systems (≥34 qubits with controlled error rates), cryogenic CMOS integrated circuits, advanced lithography tools (≤45 nm minimum resolvable feature), additive-manufacturing equipment under vacuum, and related software/technology. The notification took effect 30 days from issuance, on 23 October 2025, and is the first new SCOMET category created since the list's last major restructure, aligning India's strategic-trade-control regime with parallel US BIS, Wassenaar Arrangement, and EU dual-use list updates.
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.