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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.
BIS published a temporary final rule under DPA section 101 (following a Presidential Determination dated July 30, 2026 that recoverable critical minerals and materials are scarce and essential to national defense) requiring U.S. persons to allocate 100 percent of their monthly sales of black mass (shredded lithium-ion battery scrap containing lithium, cobalt, nickel, manganese and graphite) and tungsten waste and scrap to other U.S. persons, effectively barring export of these materials without an explicit BIS adjustment or exception. The order takes effect August 27, 2026, runs for one year through August 27, 2027, and BIS is accepting public comments through November 4, 2026 on whether additional sales requirements are needed. This is the first US DPA/export-control action targeting the recycling and secondary-materials stage of the critical minerals supply chain, rather than primary mining or refining.
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.
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. 23 of 2026 on June 22, 2026, adding 10 US entities to the Export Control Management List under the Export Control Law and Dual-Use Items Export Control Regulations. The listing prohibits Chinese exporters from supplying dual-use items to these entities and bars any global party from transferring China-origin dual-use goods to them; ongoing transactions are suspended pending MOFCOM approval. The 10 entities include the two largest non-Chinese rare earth producers — MP Materials Corp. (Mountain Pass, CA) and USA Rare Earth Inc. (Round Top, TX) — as well as eight US defence firms (Aveox, Red Cat Holdings, Teal Drones, IMSAR, Jaia Robotics, Ball Aerospace, Oshkosh Defense, L3Harris Maritime). MOFCOM explicitly framed the action as retaliation for the US DoD's June 8, 2026 update to the Section 1260H Chinese Military Companies list, which added ~80 Chinese parent firms and 188 affiliates.
On 19 June 2026, President Mamadi Doumbouya chaired a strategic meeting in Conakry with industrial, semi-industrial and artisanal gold operators and gold-buying counters, announcing that "l'exportation de l'or brut appartient désormais au passé" — a formal and permanent prohibition on exporting unrefined gold mined in Guinea. All gold must henceforth be refined domestically, primarily via the state-backed Nimba Gold Refinery (Gbessia, Conakry), before any international sale. Operators who continue exporting raw gold risk suspension or revocation of their operating licence and mining convention. The measure extends Guinea's Simandou 2040 local-transformation doctrine — already applied to bauxite and iron ore — to the gold sector for the first time.
On June 17, 2026, BIS announced a $36,184,680 civil penalty settlement with Robert Bosch GmbH (Stuttgart, Germany) — the largest-ever BIS enforcement penalty against a non-US company for Foreign Direct Product Rule (FDPR) violations. Between September 16, 2020 and September 26, 2024, Bosch exported approximately $72.4 million in MEMS sensor products and automotive software from abroad to Huawei Technologies and its Entity List affiliates without the required BIS license. Bosch filed a Voluntary Self-Disclosure and cooperated throughout; the DOJ issued the first-ever NSD declination under its newly established Corporate Enforcement Policy, declining criminal prosecution entirely.
Decision No. 190 of 2026 of Egypt's Minister of Investment and Foreign Trade Mohamed Farid, published in the Egyptian Official Gazette (الوقائع المصرية) issue No. 98 (annex / تابع) on 4 May 2026 and effective the following day, imposes a temporary US$90 per metric ton export duty on all nitrogen-based fertilizers (principally urea and ammonium nitrate) for a three-month window expiring early August 2026, with extension possible. The duty is paid in Egyptian pounds at the Central Bank of Egypt prevailing rate at the time of each transaction. Phosphatic fertilizers are excluded. The stated rationale is securing domestic supply availability during a global nitrogen-price surge driven by Russian/Ukrainian supply disruption, Iranian production losses, and seasonal demand. Egypt is the world's #7 nitrogen-fertilizer exporter (≈3.54 Mt exported in 2024); the measure quadruples the prior nominal export-tax level on the segment.
Resolution of the Government of the Russian Federation No. 431 of 17 April 2026, signed by Prime Minister Mikhail Mishustin, sets temporary export quotas on mineral fertilisers from Russia for the six-month period 1 June – 30 November 2026. The aggregate quota is approximately 20 million tonnes, comprising over 8.7 Mt for nitrogen fertilisers (urea, ammonium sulphate, UAN), over 4.2 Mt for ammonium nitrate (a separate sub-quota, suspended from 21 March – 21 April 2026 before this cycle opened), and over 7 Mt for complex fertilisers (NPK, NP, NPS, DAP, MAP). The measure continues the recurring six-month quota architecture in place since late 2021 and is the direct successor to the Dec 2024 – May 2025 cycle fixed under Resolution 1400 of October 2024 (and its subsequent extensions). Exemptions apply to EEU members, Abkhazia, South Ossetia, humanitarian-aid lots, and transit flows.
Turkey's Ministry of Trade Export General Directorate issued a circular on 6 April 2026 prohibiting exports of sulphur classified under customs tariff position 2503 (excluding sublimed, precipitated, and colloidal sulphur) effective 7 April 2026 through 30 September 2026. The measure was requested by the Ministry of Agriculture and Forestry in response to a 35–40% surge in domestic sulphur prices and supply shortages triggered by Middle East conflict disruptions to global sulphur flows. Turkey exported approximately 226,500 tonnes of sulphur in 2025, primarily to Egypt, Tanzania, Greece, and Lebanon; Tüpraş's regular 8,000-tonne monthly Mediterranean spot tender was suspended immediately. The ban compounds Russia's concurrent sulphur export ban (Decree No. 350, extended to 30 June 2026), compressing Mediterranean and East African sulphur availability during the global spring–summer fertiliser demand peak.
Government Resolution No. 350 of 31 March 2026 extended Russia's temporary ban on exports of liquid, granulated, and lump sulphur (HS 2503) through 30 June 2026. The measure was originally introduced by Resolution No. 1470 of 28 October 2025 (effective 1 November 2025) to stabilise raw-material supply for domestic mineral-fertiliser production, and had been successively extended through December 2025 and March 2026 before this latest extension. Exemptions apply to EAEU member states, Abkhazia, and South Ossetia; a concurrent GTA-recorded instrument (state-act 97135) converted certain lower-grade sulphur grades to a licensing regime rather than an outright ban.
Presidential Decree No. 193, signed by President Vladimir Putin on 25 March 2026 and in force from 1 May 2026, prohibits the export from Russia of refined gold bars (аффинированное золото в слитках) with a total weight exceeding 100 grams by individuals, legal entities, and individual entrepreneurs. Narrow exceptions apply for EAEU-destination and non-EAEU-destination movements through designated international airports (Vnukovo, Sheremetyevo, Domodedovo, and Knevichi/Vladivostok) conditional on Federal Assay Office or Federal Border Service permits. The stated rationale — curbing shadow-economy use of bullion as a foreign-currency substitute and closing capital-flight channels — is analytically inseparable from the broader post-2022 Russia counter-sanctions context and the G7 / LBMA delisting of Russian-origin gold.
Germany's Federal Economic Affairs Ministry (Bundesregierung) and BAFA issued Allgemeine Genehmigung Nr. 48 (AGG 48) on 20 March 2026, a time-limited general export licence simplifying the export of specified air-defence and maritime-defence equipment to Bahrain, Qatar, Kuwait, Oman, Saudi Arabia, the United Arab Emirates, and Ukraine, in force until 15 September 2026. Exporters may register retrospectively up to 30 days after first shipment, replacing individual-licence applications for in-scope items and materially compressing per-shipment administrative lead times. The measure is framed as part of Germany's reinforced commitment to supplying defence equipment to allies countering regional threats and Russian aggression.
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 Zimbabwe's Ministry of Mines and Mining Development, under Minister Polite Kambamura, announced an immediate and indefinite suspension of exports of all unprocessed minerals — including lithium-bearing spodumene concentrates, which had previously been exempt from the country's December 2022 ban on raw lithium ore (Statutory Instrument 213 of 2022). The directive was communicated by ministerial letter dated 17 February 2026 to the Chamber of Mines of Zimbabwe and copied to lithium producers; the suspension took effect on 25 February and explicitly covered consignments already in transit, with the Zimbabwe Revenue Authority (ZIMRA) and the Minerals Marketing Corporation of Zimbabwe (MMCZ) ordered to halt clearance at the border. The measure brings forward by roughly eleven months a lithium-concentrate export ban that had been telegraphed for January 2027, and broadens it to all raw mineral exports. The Minister cited "national interest", in-country beneficiation, transparency, and prevention of mineral export "leakages" (smuggling and under-invoicing) as the rationale. Bloomberg and Reuters reporting noted under-declaration of grade and value as a proximate trigger; the government later (April 2026) clarified that reinstated exports would require Quota Verification certificates, monthly reporting, on-site assay laboratories, and individual producer-level export ceilings — i.e. the suspension functions as a reset to a quota regime rather than a permanent embargo. Zimbabwe is the world's fifth-largest lithium producer (~6-7% of global supply on a contained-LCE basis) and exported 1.128 million tonnes of spodumene concentrate in 2025 (an 11% YoY increase). The producer base is overwhelmingly Chinese-owned: Zhejiang Huayou Cobalt (Arcadia / Prospect), Sinomine Resource Group (Bikita Minerals), Chengxin Lithium (Sabi Star), and Sichuan Yahua (Kamativi) together account for the majority of output. The ban therefore primarily disrupts Chinese midstream lithium converters in Sichuan and Jiangxi that depend on Zimbabwean spodumene feedstock, while incrementally tightening the global seaborne concentrate market. The action is structurally a continuation of the EM resource-nationalism / upstream-capture template pioneered by Indonesia's nickel-ore ban (2020) and most recently extended by the DRC's ARECOMS cobalt suspension and quota system (Feb-Oct 2025). It reinforces a pattern in which producing-country governments capture processing margin from consuming-country smelters, and it does so in a commodity (lithium) where ex-China refining capacity is still thin, magnifying near-term price impact even though the headline share of global supply removed is moderate.
India's Directorate General of Foreign Trade (DGFT), under the Ministry of Commerce and Industry, issued Notification No. 62/2025-26 on 24 February 2026 permitting the export of 25 Lakh Metric Tonnes (LMT) of wheat under HS Codes 10011900 (durum wheat - other) and 10019910 (other wheat) while keeping the headline export-policy classification as "Prohibited". A second tranche of 25 LMT was authorised by Notification No. 13/2026-27 on 27 April 2026, bringing the cumulative quota envelope to 50 LMT (5 million tonnes). Public Notice No. 05/2026-27 (30 April 2026) prescribed allocation modalities for the second tranche: 18 LMT for large exporters, 5 LMT for state trading entities and cooperatives, and 2 LMT for MSMEs, with online applications open 1-10 May 2026 and authorisations valid for six months. The mechanism partially unwinds the May 2022 blanket wheat export ban (DGFT Notification 06/2015-2020) which had been in continuous force for nearly four years, while preserving DGFT's authority to retighten via the prohibition baseline. Pre-existing government-to-government exports to meet third-country food security needs remain permitted outside the quota envelope.
The US Bureau of Industry and Security issued a final rule (RIN 0694-AK43, 91 FR 1684, signed 13 January 2026, effective 15 January 2026) revising the EAR license-review policy for exports of certain advanced-computing integrated circuits to end-users in China and Macau from a presumption of denial to case-by-case review. Eligibility is limited to commodities controlled under ECCN 3A090.a and 3A090.b with a Total Processing Performance (TPP) below 21,000 and total DRAM bandwidth below 6,500 GB/s — the band that covers NVIDIA H200 and AMD MI325X-equivalents and below. To qualify, exporters must certify (i) sufficiency of US supply such that the export will not delay domestic orders or divert foundry capacity, (ii) that aggregate TPP of advanced-node ICs exported to China or Macau will not exceed 50% of domestic shipments, (iii) compliance with end-use and end-user prohibitions, and (iv) prior performance review by a qualified independent third-party testing lab headquartered in the United States. The rule is the first material rollback of the October 2022 / October 2023 / December 2024 advanced-computing export-control architecture and operationalises the Trump-administration policy of trading H200-class chip access against Chinese cooperation on critical minerals, fentanyl precursors and Taiwan-strait restraint.
On 6 January 2026 China's Ministry of Commerce issued Announcement No. 1 [2026] "On Strengthening Export Controls on Dual-Use Items to Japan" (商务部公告2026年第1号), the first PRC export-control instrument to single out a named country other than the United States. Effective immediately on publication with no wind-down period, the measure prohibits export of all dual-use items under PRC export-control law where the end-user is the Japanese Ministry of Defense or Self-Defense Forces, the end-use is Japanese military, or — under a novel catch-all standard — the transaction would "enhance Japan's military capabilities." The standard is explicitly extraterritorial, covering transfers of PRC-origin dual-use items through third countries and in-country transfers where the end-user / end-use falls within scope. The political trigger was Japanese PM Takaichi's November 2025 Diet remarks framing a Taiwan contingency as a Japanese "survival-threatening situation" justifying SDF deployment.
Decision No. 582 of 2025 of Egypt's Ministry of Investment and Foreign Trade, published in the Egyptian Official Gazette (Issue 4 bis) on 5 January 2026, carves a narrow, fee-bearing exception into Egypt's standing export ban on raw white silica sand (originally imposed by Prime Ministerial Decree No. 108 of 2022). Shipments of raw white sand destined for production projects established inside Egypt's free zones are now permitted, but only within quantities approved by the General Authority for Investment and Free Zones (GAFI) and subject to a new export duty of US$15 per metric ton (or the EGP equivalent). Outside this free-zone exception, the general export ban on the material remains in force.
Resolution of the Government of the Russian Federation No. 2089 of 22 December 2025 sets the tariff quota for the export of wheat, meslin, barley, and corn from Russia to countries outside the Eurasian Economic Union at 20 million tonnes, effective from 15 February to 30 June 2026. The quota for rye exports is set at zero tonnes. Within the quota, exports remain subject to Russia's floating in-quota grain export duty (formula-driven, indexed to global wheat reference prices); shipments outside the quota face a duty of 50% of customs value, but not less than €100 per tonne. Humanitarian-aid shipments authorised by separate government decisions are exempt. The H1 2026 cap roughly doubles the 10.6-Mt H1 2025 quota and is calibrated to a record 137-Mt 2025/26 Russian grain harvest.
The National Defense Authorization Act for Fiscal Year 2026 (P.L. 119-60), signed into law on 18 December 2025, expands the Department of Defense's existing "covered materials" domestic- sourcing restriction (which already barred DoD contracting for SmCo/NdFeB magnets, tantalum and tungsten sourced from China, Russia, Iran or North Korea) to add gallium, germanium and molybdenum under Section 844. Restrictions on materials "melted or produced" in a covered nation take effect 31 December 2026, widening on 1 January 2027 to also cover materials "mined, refined, or separated" in a covered nation; the gallium/germanium additions specifically phase in on 18 December 2027. The same NDAA bundles two related supply-chain provisions: Section 867 gives DoD broader authority (contracts, grants, other-transaction agreements, equity-style investments, and anti-market-manipulation subsidies) to invest in the domestic industrial base for critical minerals, microelectronics, machine tools and other defense-relevant capacity, and Section 842 bars DoD from procuring advanced batteries whose cells or key components are owned, sourced, refined or produced by a foreign entity of concern, phased in 2028-2031.
The UK Export Control (Amendment) (No. 2) Regulations 2025 (SI 2025/1197) entered into force on 16 December 2025, extending the UK's strategic export control regime to cover quantum computing hardware (ECCN-aligned 4A506), advanced and cryogenic semiconductor technologies (3A501, 3A504, 3B501), and associated software and technology categories. The regulations also transfer existing national controls on quantum and advanced semiconductor items from the Export Control Order 2008 into the UK's assimilated Dual-Use Regulation (retained EU 428/2009 as amended), harmonising the UK's dual-use schedule with Wassenaar Arrangement 2024 updates. The action is explicitly calibrated as "Wassenaar Minus One" — aligning UK controls with the US BIS (EAR / ECCN framework) and EU (Regulation 2021/821 as amended) without requiring multilateral consensus on each item. It is the first UK statutory instrument since Brexit to add substantial new technology-specific dual-use controls targeting advanced semiconductor and quantum capabilities.
On 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.
On 20 November 2025 the White House and US Department of Commerce / Bureau of Industry and Security (BIS) authorised Abu Dhabi AI holding company G42 to import advanced computing chips — equivalent to approximately 35,000 Nvidia GB300 Blackwell processors — under the UAE-pioneered Regulated Technology Environment (RTE) compliance framework. The RTE is an Emirati-designed technology governance and audit architecture, developed by G42 and approved under BIS guidelines, with binding UAE-side controls to prevent onward diversion to foreign adversary nations. The authorisation accelerates the Stargate UAE project — a 1 GW AI compute cluster being built by G42 for OpenAI in partnership with Oracle, Cisco, NVIDIA, and SoftBank Group — and represents the first concluded major country-level advanced-compute authorisation following the May 2025 rescission of the Biden-era AI Diffusion Rule.
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) published a draft amendment to the Strategic High-Tech Commodities (SHTC) export control lists on 18 November 2025, subject to a 60-day public-preview period, adding 18 items in three new categories — advanced 3D printing equipment (metal-powder-bed- fusion, laser-sintering, electron-beam-melting capable systems), advanced semiconductor equipment (CMOS chips, low-temperature cryogenic cooling, scanning electron microscope equipment, cryogenic wafer probers), and quantum computers (general-purpose programmable quantum computing systems). Exporters must obtain MOEA-ITA prior approval before shipment; permits will be issued only after confirming goods will not be used in weapons-of-mass-destruction programmes.
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.
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.
On October 31, 2025, Bulgaria's National Assembly voted 135-4 (42 abstentions) to adopt a decision introducing a temporary measure restricting the export and intra-EU supply of petroleum products — chiefly diesel and aviation fuel — to all destinations, including fellow EU member states. The measure took effect around November 1, 2025 upon publication. Gasoline was excluded because domestic production exceeds internal demand. The ban is a direct domestic-supply-security response to US OFAC's October 22, 2025 SDN designation of Lukoil (see responds_to), whose Burgas refinery supplies roughly 80% of Bulgaria's fuel market; lawmakers cited the risk that sanctions exposure could disrupt Lukoil's export activity and drain the volumes needed to cover domestic demand. Exemptions cover refuelling of ships and aircraft and deliveries to NATO and EU member-state armed forces under the common defence policy.
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.
President Peter Mutharika signed an executive order effective 21 October 2025 prohibiting the export of all raw, unprocessed minerals extracted in Malawi, covering uranium, rare earth elements, niobium, graphite, tantalum, bauxite, rutile, gold, copper, diamonds, heavy mineral sands, and all other minerals. Minerals that have been processed, refined, or value-added in Malawi are exempt. The order aligns with an announced National Mining Corporation to oversee mineral production and processing, and introduces fines and sanctions under Malawi law for violations.
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.
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.
The Bureau of Industry and Security (BIS), within the U.S. Department of Commerce, published a final rule in the Federal Register on September 30, 2025 (FR Doc 2025-18992) rescinding the April 30, 2024 Firearms Export License Requirements interim final rule in its entirety, with the sole exception of preserving the new Export Control Classification Numbers (ECCNs) it had introduced for firearms and ammunition. The rule also amends the EAR to remove the Congressional notification requirement for certain semi-automatic firearms license applications. It is effective on publication.
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.
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.