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

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.

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.

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.

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.

China's Ministry of Commerce and General Administration of Customs jointly announced an export licensing regime covering eight gallium-related items (including gallium metal, gallium arsenide, gallium nitride wafers and ingots) and six germanium- related items (including germanium metal, germanium oxide, germanium tetrachloride). Effective 1 August 2023, exporters must obtain a dual-use-item licence from MOFCOM citing the end-user and end-use, with licences granted at MOFCOM's discretion. The measure was framed as protecting national security and interests, though the timing immediately followed the Dutch ASML DUV controls and US chip-equipment escalations.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) on 8 February 2022 to add 33 persons — all based in China — to the Unverified List (UVL) under EAR §744.15(c), on the basis that BIS could not satisfactorily complete end-use checks for these entities for reasons outside US Government control. Placement on the UVL bars exporters from using any EAR license exception when shipping controlled items to listed parties and requires exporters to obtain a certified UVL Statement from the entity or secure a BIS export licence. Sectors represented include semiconductor manufacturing equipment, optoelectronics, UAVs, specialty chemicals, and biotechnology.

The US Bureau of Industry and Security added five Xinjiang-based entities to the Entity List on June 24, 2021, citing their roles in human rights violations and forced labor against Uyghur, Kazakh, and other Muslim minority populations in the Xinjiang Uyghur Autonomous Region. The five entities — four major polysilicon and silicon producers plus the Xinjiang Production and Construction Corps (XPCC) paramilitary body — are subject to a presumption-of- denial licensing policy for most items. Together the four polysilicon companies supplied a significant fraction of global polysilicon feedstock used in solar panel manufacturing.