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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 31 December 2025, China's Ministry of Commerce and General Administration of Customs jointly published Announcement No. 91 of 2025, releasing the 2026 edition of the Catalogue of Dual-Use Items and Technologies Subject to Import and Export Licence Administration, effective 1 January 2026. The update replaces the 2025 catalogue and is issued under the Export Control Law of the PRC and the Regulations on Export Control of Dual-Use Items. Key additions to the export-licensing perimeter include samarium, gadolinium, and lutetium compounds — mid-to-heavy rare earths critical for permanent magnets (EV motors, wind turbines), phosphors (medical imaging, displays), and defence applications — requiring MOFCOM export licences for all covered shipments from 1 January 2026.
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.
Government Resolution No. 2076 of 19 December 2025 replaces Russia's standing ban on husked rice and rice-paddy exports (in force July 2022 – 31 December 2025) with a 200,000-tonne tariff-rate quota for calendar year 2026. Within the quota, exports to countries outside the Eurasian Economic Union face a 0% duty; shipments above the cap are charged 50% of customs value. The switch from an outright ban to a managed quota reflects Russia's view that domestic rice production now fully covers internal-market needs and that a quota-based mechanism can stimulate exports while preserving a price-stabilisation backstop.
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 11–12 December 2025, China's National Development and Reform Commission (NDRC) convened a special meeting with major phosphate fertiliser producers, traders, and industry associations, instructing them to suspend phosphate fertiliser exports in principle until August 2026 to concentrate supply on the domestic market and stabilise prices ahead of the 2026 spring planting season. The measure covers diammonium phosphate (DAP), monoammonium phosphate (MAP), triple superphosphate (TSP), and compound NPK fertilisers. China supplied roughly 40% of global phosphate fertiliser exports before the ban; Chinese export volumes in Q1 2025 fell to ~111,000 t versus a three-year average of 785,000 t for the same period.
Vietnam's 15th National Assembly adopted Law No. 147/2025/QH15 ("Law amending and supplementing some articles of the Law on Geology and Minerals") on 11 December 2025 by 421 of 432 deputies in favour (89.01%), at the 10th session, with effect from 1 January 2026. The amendment slots a dedicated rare-earth framework into the parent Law No. 54/2024/QH15, classifying rare earths as "special strategic" minerals subject to strict state management. Raw rare-earth ore export is prohibited; only state-designated or state-approved enterprises may explore, exploit, process and use rare earths; all activity must conform to a national rare-earth strategy and master plan. The state centralises geological data, regulates rare-earth import/export flows according to national needs, and builds strategic stockpiles. The amendment converts the 2024 framework law's general domestic-supply priority into an explicit raw-export ban for the world's second-largest known rare-earth resource holder.
On 9 December 2025, China's Ministry of Commerce (MOFCOM) and General Administration of Customs jointly issued Announcement No. 79 of 2025, reinstating an export-licence management system for ~300 HS-coded steel products effective 1 January 2026. Exporters must obtain a per-contract licence supported by a manufacturer-issued product quality inspection certificate; licences are issued by MOFCOM (for centrally-administered SOEs) and provincial / sub-provincial commerce departments. The regime is the first reinstatement of Chinese steel-export licensing in 16 years (since 2009) and applies the export-licensing instrument — previously used for critical minerals and dual-use goods — to a non-critical bulk commodity for the first time.
Russia's Government adopted Resolution N° 1958 on 29 November 2025, amending Resolution N° 313 of 9 March 2022 to add eight commodity positions to Appendix 3 — the list of dual-use goods banned for export to "unfriendly" states. The added items are specialty electro-optical and semiconductor materials: lithium niobate, zinc telluride, gadolinium-gallium garnet, gallium arsenide, gallium phosphide, unprocessed and processed quartz wafers/plates, and polished tellurium-oxide prisms. These materials are inputs to electro-optical components (modulators, acousto-optic devices, IR/laser optics) with both civil and military (guidance, imaging) applications. The measure took effect 1 December 2025 and runs through the underlying ban's 31 December 2027 expiry; it applies to all countries except Eurasian Economic Union member states.
Russia's Government adopted Resolution N° 1947 on 28 November 2025, extending for a fourth consecutive six-month period the temporary ban on the export of waste and scrap of precious metals and of electrical and electronic equipment used principally for precious-metals recovery. The restriction runs from 1 December 2025 through 31 May 2026, covering waste and scrap of gold, silver, platinum, palladium, rhodium, iridium, osmium, and ruthenium, as well as metals plated or clad with precious metals. Carve-outs apply for cathode antimony ingots and small laboratory samples (≤500 g per batch) shipped by refineries for quality verification.
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 Ministry of Economy, Trade and Industry amended the Export Trade Control Order (輸出貿易管理令) to add four technology categories to the prior-notification-of-transfer list under the Technology Management Scheme through Public-Private Dialogue (TMS-PPD): quantum-dot materials, TADF (thermally-activated delayed fluorescence) emissive materials, phase-difference film, and flexible endoscopes. Announced 11 November 2025, promulgated 19 November 2025, and effective 19 January 2026. This is the first list-control update produced by the TMS-PPD mechanism, which was established in December 2024 as an annual METI–industry review process for adding emerging-technology items to prior-notification controls outside the slower Wassenaar Arrangement / FEFTA catch-all channels.
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.
China's Ministry of Commerce on 9 October 2025 issued Announcements No. 61 and No. 62, jointly constituting the largest single architectural escalation of PRC export controls to date. No. 61 expands the controlled rare-earth list from 7 to 12 of 17 elements (adding holmium, erbium, thulium, europium, ytterbium) and — for the first time — imposes extraterritorial application via a 0.1% de-minimis rule, a foreign-direct-product (FDP) rule, and a 50%-affiliate rule, directly mirroring US BIS architecture. No. 62 places rare-earth extraction, smelting, separation, magnet manufacturing, and recycling technologies (including IP licensing, investment, and provision to foreign persons) under export licensing. PRC-direct exports were controlled from publication; the de-minimis and FDP offshore-items provisions were due to take effect 1 December 2025. On 7 November 2025 MOFCOM Announcement No. 70 suspended both measures until 10 November 2026 as part of the post-APEC Trump-Xi tariff detente — see amendments block.
The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 29 entries — 26 entities and 3 addresses — to the Entity List under the destinations of China (19), Turkey (9), and the United Arab Emirates (1). BIS determined these parties were diverting US-origin items to Iran, including to parties already on the BIS Entity List and on OFAC's Specially Designated Nationals (SDN) List, in support of Iranian drone-parts and electronics-procurement networks. The rule is a final rule effective October 8, 2025; new license requirements apply to all items subject to the EAR for these listed parties under a presumption-of-denial review policy.
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.
Russia's government imposed a temporary ban on exports of diesel fuel, marine (bunker) fuel and other gas oils (EAEU HS codes 2710 19 421 0 - 2710 19 429 0), including volumes purchased on exchange trading, effective 1 October 2025. The measure was framed as a domestic fuel-market stabilisation tool and initially exempted direct refinery producers from the ban. Russia is one of the world's largest diesel/gasoil exporters, so a full-coverage export halt on these grades has global gasoil-market significance, not just a regional effect. The ban has since been extended and tightened four times through mid-2026 (see amendments).
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.
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.