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

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).

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.

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 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.

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.

South Korea's Ministry of Trade, Industry and Energy issued the 36th amendment to the Public Notice on Export and Import of Strategic Items (전략물자수출입고시) as MOTIE Notice No. 2025-20, with promulgation on 24 February 2025 and effect from 28 February 2025. The amendment adds 21 advanced-technology items and technologies — including quantum computers, AI-class semiconductors, 3D-printing equipment, isotopes for quantum computing, ultra-low-temperature measurement equipment, and high-temperature coatings — to the Strategic Items List, implementing recent updates from the Wassenaar Arrangement, Nuclear Suppliers Group, Missile Technology Control Regime, and Australia Group multilateral export-control regimes. The same amendment introduces a humanitarian-medical-device carve-out for exports of diagnostic X-ray and radiographic imaging equipment to Russia, simplifies end-user verification (intermediaries deemed final end-user where verification is "extremely difficult"), extends the post-transaction reporting period from 7 days to 3 months, creates a self-disclosure system for non-compliance, and allows one-time extensions of individual export licences beyond original validity.

On 22 February 2025 the Authority for the Regulation and Control of Strategic Mineral Substance Markets (ARECOMS) of the Democratic Republic of the Congo issued Decision No. 001/ARECOMS/2025 imposing a four-month suspension of all cobalt exports — industrial and artisanal — in response to a multi-year cobalt price collapse driven by structural oversupply from CMOC's Tenke Fungurume and Kisanfu mines. The DRC accounts for roughly 70-76% of global mined cobalt, so the ban removed the dominant source of feedstock from the seaborne market. The ban was extended in late June 2025 by another three months, then on 10 October 2025 ARECOMS issued Decision No. 005/ARECOMS/2025 lifting the outright suspension and replacing it with a hard annual export quota: 18,125 t for the November-December 2025 transition window, then 96,600 t per year for 2026 and 2027. The annual ceiling consists of an 87,000 t "base quota" distributed pro-rata using each producer's January 2022 - December 2024 historical export volumes, plus a 9,600 t "strategic quota" allocated at ARECOMS' sole discretion to projects of national strategic importance. Allocations for Q4 2025 went disproportionately to the largest incumbents: CMOC received 6,500 t (Tenke Fungurume + Kisanfu), Glencore 3,925 t (Kamoto + Mutanda), and Eurasian Resources Group 2,125 t (Metalkol). CMOC's award is far below its ~115 kt 2024 production rate, structurally capping the world's top cobalt producer below 30% of its operating capacity. Exporters must obtain a Quota Verification Certificate (AVQ) from ARECOMS, submit to joint sampling, weighing, sealing and physical inspection by multiple government agencies, and prepay the 10% mining royalty within 48 hours of declaring origin and sale. ARECOMS reserves the right to revise quotas quarterly in case of "significant imbalance in the cobalt market," and explicitly retained discretion to re-set 2027 volumes. The measure is the EM resource-nationalism complement to Indonesia's nickel-ore ban template, applied to the single material where one country has the most concentrated global supply share.

On 6 February 2025 the South African Revenue Service updated its Prohibited and Restricted Imports and Exports list to require an International Trade Administration Commission (ITAC) export permit for a broad basket of base-metal tariff headings: 72.04 (excl. 7204.21), 7404.00, 72.05, 72.06, 72.07, 72.18, 72.24 (iron/steel waste, ingots, semi-finished and granules), 74.02, 74.03, 74.05, 74.06 (unrefined/refined copper and copper powders), 76.01, 76.03, 76.04 (unwrought aluminium, powders and bars), 78.01 (unwrought lead), 79.01 (unwrought zinc) and 80.01 (unwrought tin). The same update removed the export-permit requirement from six copper sub-headings (7403.12, 7403.13, 7403.19, 7403.21, 7403.22, 7403.29) and added several machinery tariff headings (8417.10, 8417.80, 8462-series) to the import-permit list.

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.

After a comprehensive two-year mining ban (August 2023–April 2025), Wa State authorities formally opened new three-year licence applications for mining, processing, and prospecting in Man Maw in February 2025, with permits issued to operators from approximately April 2025. The restart regime imposes a 30% universal tax-in-kind on all tin concentrate exports plus an additional 5% first-batch concentrate levy to fund joint mine dewatering, materially re-pricing approximately 10% of global tin concentrate supply. Shipments recovered to ~1,300 tonnes contained tin per month by November–December 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.

On 16 January 2025 the US Bureau of Industry and Security published an interim final rule (90 FR 4598; FR Doc 2025-00723) creating new ECCN 3A069 for high-parameter flow cytometers and liquid chromatography mass spectrometers specially designed for top-down proteomics, plus new ECCN 3E069 for related development and production technology. Items previously controlled under the catch-all ECCN 3A999 are migrated into the dedicated 3A069 classification, which carries National Security (NS), Regional Stability (RS), and Anti-Terrorism (AT) controls. Licensing policy is presumption of denial for destinations in Country Group D:1 and D:5, Macau, and Country Group E (i.e. China, Russia, Iran, North Korea, Cuba, Syria, Venezuela). The rule also adds new EEI/AES filing requirements (§ 758.1(b)(11)) for all 3A069 exports to Country Group D destinations. Public comments were accepted until 17 March 2025.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 11 entities under 11 entries to the Entity List, all listed under the destination of China, People's Republic of (China). The rule also revises one existing entry on the Entity List under the destination of India. BIS determined the added entities have been involved in, are involved in, or pose a significant risk of becoming involved in activities contrary to the national security or foreign policy interests of the United States. License requirements apply to all items subject to the EAR with a presumption-of-denial review policy. The rule was effective on publication, January 16, 2025. This action is the companion piece to the same-day 16-entity Sophgo-cluster addition (FR 2025-00480) — together totalling the "27 Chinese companies" referenced in trade-press coverage.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 16 entities to the Entity List under the destinations of China (14) and Singapore (2). The additions concentrate on the Sophgo Technologies cluster and a set of affiliated PRC fabless / system houses (Suanze, Suanxin, Suanhu, Suanli, Suanneng, Sophon, Quliang, Shunhua) plus two Singapore entities (Sophgo Technologies Pte. Ltd., PowerAir Pte. Ltd.) acting as offshore extensions of the same group. BIS cites involvement in "supporting or directly contributing to the development of advanced computing integrated circuits" that further PRC advanced-weapons, WMD, and high-tech surveillance programs. License requirement covers all items subject to the EAR with a presumption-of-denial review policy. The rule was effective on publication, January 16, 2025.

The Netherlands extended its national export-control measure under the Besluit Strategische Goederen to a new equipment class: specific optical and e-beam measuring and inspection systems used in advanced semiconductor production (capable of detecting defects at 21 nm and below). A national licence issued by the Dutch government (CDIU / BUZA / EZ joint approval) is now required for exports to all destinations outside the EU. The measure was announced by Minister Klever in the Government Gazette on 15 January 2025 and took effect 1 April 2025, directly affecting ASML's Hermes Microvision (HMI) subsidiary and ASM International (ASMI).

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 entities under 13 entries to the Entity List, listed under the destinations of Burma (1), China (11), and Pakistan (1). The PRC additions concentrate on the optics/photonics, RF/microwave, and military-civil-fusion research-institute layer of China's military-modernization stack — including CAS Changchun Institute of Optics, Fine Mechanics and Physics (CIOMP), Shanghai Institute of Optics and Fine Mechanics (SIOM), Peng Cheng Laboratory, Ji Hua Laboratory, and the Yaguang/Chengdu RML defense-electronics cluster — with explicit references to support for hypersonic-weapons development. The Burma entity is Telecom International Myanmar (Mytel), added for providing surveillance services and financial support to the post-coup military regime; the Pakistan entity (Emerging Future Solutions Pvt Ltd) was added for contributions to Pakistan's ballistic-missile programme. All 13 entries carry a license requirement for all items subject to the EAR with a presumption-of-denial review policy and no license exceptions. The rule was effective on publication, January 6, 2025, with a savings clause through February 5, 2025 for goods already en route.

On 23 December 2024 the US Bureau of Industry and Security published a final rule (89 FR 104408; FR Doc 2024-30425; RIN 0694-AJ83) amending the Export Administration Regulations to implement decisions adopted at the Australia Group's 2023 and 2024 plenary meetings. The rule adds new ECCN 2B352.k controlling instruments for the automated chemical synthesis of peptides that are partly or entirely automated and capable of generating peptides at a system-synthesis scale of 1 mmol or greater, finalising the April 2023 BIS proposed rule. It also adds dipropylamine to ECCN 1C350.d.11, neosaxitoxin to ECCN 1C351.d.12, revises the 1C351.d.3 entry from "botulinum toxins" to "botulinum neurotoxins" to capture all serotypes, adds a "minimum detection limit" definition for toxic-gas monitors in 2B351.a, and explicitly captures single-use centrifugal separators in 2B352.c. License requirements (CB, AT, CW where applicable) apply for export to non-Australia-Group destinations; the rule is effective on publication.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations by adding 8 entities to the Entity List under the destinations of Burma (2), China (2), and Russia (4), citing actions contrary to US foreign-policy interests, primarily enabling human-rights violations through aerial attacks on civilians (Burma), Uyghur surveillance (China), and facial-recognition targeting of protesters (Russia). All designated entities require licenses for all items subject to the EAR with a presumption of denial. The rule was effective immediately on publication, December 11, 2024.

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.

The US Bureau of Industry and Security issued its largest single export-control package targeting China's semiconductor industry on 2 December 2024, with three layered measures (final rules published in the Federal Register 5 December 2024). First, controls on high-bandwidth memory (HBM) above set performance thresholds — blocking the memory architecture that is foundational to AI training. Second, additions of 24 semiconductor manufacturing equipment item types to the Commerce Control List, covering deposition, etch, ion- implant, advanced packaging, and metrology categories. Third, Entity List designations for 140+ entities, the bulk Chinese semiconductor companies + equipment makers + investment vehicles, including major Chinese fab tooling firms. The package triggered MOFCOM's same-day-following retaliation (filed: 2024-12-03-china-mofcom-ge-ga-sb-export-ban-us).

The US Bureau of Industry and Security amended the Export Administration Regulations to impose a new "Regional Stability – Pakistan" (RS-PAK) licence requirement on exports, reexports, and in-country transfers to Pakistan of items classified under six previously-uncontrolled-for-Pakistan ECCNs: 1B999, 2A992, 2B999 (excluding 2B999.h.2), 3A992, 3A999, and 6A996. The covered items — process-control equipment, high-pressure piping and valves, oscilloscopes, electronic test equipment, magnetometers, and related dual-use industrial gear — are associated with unsafeguarded nuclear and ballistic-missile end-uses. Licence applications are reviewed case-by-case to assess diversion risk to Pakistan's nuclear weapons or ballistic missile programmes, and to entities already on the Entity List or front companies acting on their behalf. Issued as a final rule under ECRA §1762(a) (no notice-and-comment); originally effective 25 November 2024 with the corresponding amendatory instructions, with the substantive licence requirement effective 26 December 2024 (post C1-2024-27648 correction published 29 November 2024).

Council Regulation (EU) 2024/2897 of 18 November 2024 amends Regulation (EU) 2023/1529 (restrictive measures over Iran's military support to Russia's war against Ukraine and to armed groups in the Middle East and Red Sea region). It replaces Annex II with an expanded list of goods and technology whose sale, supply or export to Iran is prohibited where they could enable UAV or missile production, across ten technology categories, and adds Article 2a, a prohibition on transactions with the ports listed in Annex IV (Amirabad and Anzali). It entered into force on publication in the Official Journal.

Government of Russia Resolution No. 1544, signed by Prime Minister Mishustin on 14 November 2024 and published 15 November 2024, amends Resolution No. 313 of 9 March 2022 (the framework counter-sanctions list of goods restricted for export to "unfriendly" jurisdictions) by adding HS code 2844 20 — uranium enriched in U-235 and its compounds — to Annex 2. The amendment imposes a temporary export ban on enriched uranium to the United States and to legal entities incorporated in US jurisdiction, in force from 16 November 2024 through 31 December 2025. Exports are permitted only under one-off licences issued by the Russian Federal Service for Technical and Export Control (FSTEC). The measure is an explicit tit-for-tat response to the US Prohibiting Russian Uranium Imports Act (Public Law 118-50, 13 May 2024).

The US Bureau of Industry and Security (BIS) final rule (89 FR 87261; FR Doc 2024-25411) added 40 entities under 42 entries plus four addresses to the Entity List under the destinations China (11), India (5), Malaysia (2), Russia (13), Singapore (1), and Turkey (14), and modified 52 existing entries across China, Estonia, Finland, India, Turkey, the UAE and the UK. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish, Indian, Malaysian and Singaporean entities listed for transshipping controlled US-origin items to Russian defense end users; the 13 Russia entries cover chemical and biological warfare R&D and defense procurement networks. License requirement is "all items subject to the EAR" with a policy/presumption of denial; four China addresses get the narrower "CCL + EAR99 supp. 7" scope. Effective on publication 2024-11-01.

On 31 October 2024, South Korea's Ministry of Foreign Affairs announced strengthened export controls in response to North Korea's long-range ballistic missile launch earlier that day. The measure designates 15 "North Korea-customized" watch-list items across the solid-fuel missile production chain — including ammonium perchlorate, sodium chloride, liquid thiokol, carbon fiber, glass fiber fabric, thermal batteries and inertial-guidance components — that North Korea finds difficult to produce domestically. It operates under Korea's existing Special Notice on Trade for Fulfilling International Peace and Security Obligations, building on the June 2016 Nuclear and Missile Surveillance Items framework and Korea's NSG/MTCR commitments.

Resolution of the Government of the Russian Federation No. 1400 of 23 October 2024, signed by Prime Minister Mikhail Mishustin, sets temporary export quotas on mineral fertilisers from Russia for the six-month period 1 December 2024 – 31 May 2025. The aggregate cap is approximately 19.2 million tonnes, comprising about 11.2 Mt for nitrogen fertilisers and roughly 8 Mt for compound (NPK / NP / NPS) fertilisers. As with prior cycles, the quota is allocated across exporters by historical share and motivated by domestic-market supply stabilisation rather than revenue capture. Russia is the world's largest mineral-fertiliser exporter (~15-20% of global trade depending on segment), so the semi-annual quota is one of the principal global ag-input policy instruments.

Bureau of Industry and Security final rule (89 FR 84460, Doc 2024-24562) adding 26 entities to the Entity List across four destinations: six in China (aviation simulation for PLA modernisation; procurement for Iran WMD/UAV programs; evasive conduct), one in Egypt and three in the UAE (acquiring US civil aircraft parts for Russian buyers post-Ukraine invasion), and sixteen in Pakistan (nine front companies of Advanced Engineering Research Organization for Pakistan's cruise-missile and strategic-UAV programs, plus seven contributing to Pakistan's ballistic- missile program). The rule also removes two existing entries. All additions are licensed under a presumption-of-denial policy for all EAR-subject items.

In a final rule published at 89 FR 84766 (FR Doc 2024-23932), the US Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) to remove BIS licence requirements on certain spacecraft and related items — including remote-sensing spacecraft and on-orbit servicing, assembly, and manufacturing (OSAM) items — for exports and reexports to Australia, Canada, and the United Kingdom. The rule is effective immediately on publication (23 October 2024) and is part of a three-rule package modernising the US space-related export-control regime (companion IFR 2024-23958 broadens controls relief for ~40 additional destinations; companion proposed rule 2024-23975 floats a new License Exception Commercial Space Activities). The AU/CA/UK carve-out builds on the trilateral National Technology and Industrial Base (NTIB) framework.

Premier Li Qiang signed State Council Decree No. 792 on 19 October 2024 promulgating the Regulations of the People's Republic of China on Export Controls for Dual-Use Items, with effect from 1 December 2024. The regulation, organised in six chapters and 50 articles, consolidates the previously fragmented nuclear / biological / chemical / missile dual-use control regimes into a single State Council framework operationalising the 2020 Export Control Law. It introduces a control-list / temporary-control / watchlist architecture, a statutory end-user / end-use commitment regime, transit / transhipment / re-export controls, extraterritorial reach over PRC items downstream, and explicit linkage to the Anti-Foreign Sanctions Law. On 15 November 2024 MOFCOM, MIIT, GAC and SCA jointly issued Announcement No. 51 of 2024 publishing the consolidated Dual-Use Items Export Control List with a unified five-character ECCN-style coding system, also effective 1 December 2024.

In an interim final rule (IFR) published at 89 FR 84770 (FR Doc 2024-23958), the US Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to revise controls on spacecraft and related items. The rule shifts the reasons for control on "specially designed" parts, components, accessories, and attachments under ECCNs 9A004.x and 9A515.x from National Security Column 1 / Regional Stability Column 1 (NS1/RS1) to NS2/RS2 — eliminating BIS licensing requirements for roughly 40 destinations that only face NS2/RS2 controls on the Commerce Country Chart. The IFR also broadens License Exception STA-related provisions and expands support for NASA cooperative programmes. It is one of three companion rules (with FR Doc 2024-23932 and a parallel proposed rule on a new License Exception Commercial Space Activities) issued the same day to modernise the US space-related export-control regime.

Norway's Ministry of Foreign Affairs amended the Eksportkontrollforskrift (Regulations on the export of defence- related products, dual-use items, technology and services) to add a new national control list — Annex III ("List III") — for emerging and disruptive technologies not yet covered by the EU dual-use list. Exports of items on Annex III require a licence from the Ministry of Foreign Affairs regardless of destination, including a catch-all licensing obligation. Controls cover semiconductor manufacturing equipment (including dry-etch apparatus), enriched silicon/germanium substrates, high- performance integrated circuits, quantum computers above specified controlled-qubit thresholds, quantum software and technology, software/technology for reverse-engineering integrated-circuit layouts, and additive-manufacturing equipment for metal/alloy components. The amendment, announced 3 October 2024 and effective 1 November 2024 (with a one-month transitional period), aligns Norway with parallel national measures adopted by the United States (BIS 6 Sep 2024 emerging- technology IFR), the Netherlands, the United Kingdom, Japan, Spain, Denmark and Finland.

The US Bureau of Industry and Security (BIS) published an interim final rule (89 FR 80064; FR doc 2024-22587) amending the Export Administration Regulations (15 CFR 748.15) to expand the Validated End User (VEU) program with a new "Data Center VEU Authorization" pathway. The rule lets BIS pre-authorize specified data-center operators in third countries to receive advanced computing integrated circuits (ECCNs 3A090, 4A090 and related) and related technology without individual export licenses, conditional on vetted security plans, end-use monitoring, and reporting. Country Group D:5 destinations — China, Russia, Iran, Belarus, Venezuela, Cuba and 17 other arms-embargoed states — are categorically excluded. Eligible destinations include Egypt, Laos, Moldova, Oman, Pakistan, Qatar, Saudi Arabia, Turkmenistan, and the UAE — extending the US chip-equipment perimeter into a managed trusted-data-center channel for Gulf, MENA, and Central Asian AI build-out.

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

MOTIE brought the 35th amendment of the Public Notice on Trade of Strategic Items into force on 9 September 2024, adding 243 items (notice Annex 2-2 numbers 1160-1402) to the situational-licence list for Russia and Belarus, taking that list to 1,402 items. The added items are described as having a high likelihood of military diversion (metal-cutting machinery, machine-tool parts, optical-equipment parts, sensors). Exports of the added items are prohibited in principle from 9 September, with licence applications admitted only for contracts concluded by 8 September and case-by-case categories such as exports to Korean companies' local subsidiaries. The same release tightens administrative penalties for deliberate export-control violations.

The US Bureau of Industry and Security issued a final rule on 5 September 2024 (effective 6 September 2024, published in the Federal Register on the same day as 89 FR 73285) establishing multilateral export controls on four categories of emerging technologies: (1) quantum computing items including quantum computers, related cryogenic / control / measurement systems, and certain quantum software; (2) gate-all-around field-effect transistor (GAAFET) production technology — the next-node semiconductor architecture beyond FinFET; (3) advanced additive-manufacturing equipment for metals + alloys; (4) certain biotech-related items added in a parallel rule on 12 September 2024. The rule operates without country exceptions for some categories, with multilateral coordination via Wassenaar + Australia Group + Nuclear Suppliers Group frameworks.

Cabinet Resolution No. 97 of 2024 is the implementing regulation of UAE Federal Decree-Law No. 43 of 2021 on Commodities Subject to Non-Proliferation. It operationalises the UAE's horizontal dual-use export-control regime, empowering the Executive Office for Control & Non-Proliferation (EOCN) to designate prohibited and restricted goods on the National Control List and to issue export/transit/re-export permits within 20 working days. The Control List covers nuclear materials, chemicals and precursors, electronics, telecommunications, sensors and lasers, navigation systems, avionics, marine and aerospace equipment, propulsion systems, and "national controlled commodities" (armoured vehicles, autonomous equipment). This is the regulatory architecture under which post-G42 advanced AI-chip outbound flows from the UAE are licensed.