Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

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.

On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.

On 15 October 2025 the German Federal Cabinet adopted the Microelectronics Strategy of the Federal Government, jointly presented by the Federal Ministry for Research, Technology and Space (BMFTR) and the Federal Ministry for Economic Affairs and Energy (BMWE). The strategy is the first comprehensive cabinet-adopted German microelectronics policy framework in over a decade and operationalises Germany's contribution to the European Chips Act envelope. It is organised around three pillars — Research, Skilled Labour and Production — and creates a "Chips Office" to coordinate stakeholder interaction and implementation. It establishes a competence centre for chip design and a flagship "supercomputer in the car" project, and is framed as a key implementation instrument under the High-Tech Agenda Germany (HTAD) and as Germany's contribution to the September 29 2025 Semicon Declaration signed by all 27 EU member states calling for a revised EU Chips Act II.

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.