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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 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.

On 24 February 2026 China's Ministry of Commerce simultaneously issued Announcement No. 11 and Announcement No. 12 [2026], activating for the first time the Control List (受控名单) mechanism under Article 28 and the Watch List (关注名单) mechanism under Article 26 of the Dual-Use Export Control Regulations (effective 1 December 2024), designating 40 Japanese entities in total. The Control List (20 entities, led by Mitsubishi Heavy Industries Shipbuilding Co.) imposes an absolute prohibition on any person or entity worldwide supplying PRC-origin dual-use items to listed parties; the Watch List (20 entities, led by SUBARU Corporation) bars general licensing and requires exporters to file risk assessments and non-military-use commitments. MOFCOM framed both measures as a response to Japan's "remilitarization" trajectory, escalating well beyond the blanket enhanced- review framework established by Announcement No. 1 [2026] in January.

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.

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 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.

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.

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.

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 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.

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.

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.

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.

BIS published an interim final rule (FR Doc 2025-00711, 90 FR 4544-publication slot; companion to the AI Diffusion Framework signed three days earlier) revising the EAR to add explicit due-diligence procedures for advanced computing integrated circuits captured by ECCN 3A090. The rule (i) creates an Authorized IC Designer / Approved IC Packager regime so that foundries and OSATs can identify trustworthy customers via lists maintained by BIS, (ii) imposes new front-end-fabricator reporting requirements for any 3A090.a IC produced for an authorized IC designer to give the US government supply-chain visibility, and (iii) adjusts the scope of covered advanced-computing items. Effective 16 January 2025; compliance required from 31 January 2025; comment period extended to 14 March 2025. The rule was immediately followed by the 16 January Entity List additions (Sophgo et al.) targeting circumvention paths and was technically amended on 14 February 2025 to narrow the RS license requirement to ECCN 3A090.a only.

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

China's Ministry of Commerce announced on 3 December 2024 (MOFCOM Announcement No. 46 of 2024) a formal ban on dual-use exports to the United States of gallium, germanium, antimony and superhard materials including diamond and cubic boron nitride. The measure also imposed strict end-use review on graphite exports to the US, with extra scrutiny of military end-uses. It came one day after BIS issued a major export- control package on 2 December 2024 expanding controls on Chinese semiconductor equipment and adding 140 entities to the Entity List, and was framed by MOFCOM as a national- security countermeasure.

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

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

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

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

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

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

The US Bureau of Industry and Security (BIS) final rule (89 FR 68544; FR Doc 2024-19130) added 123 entities under 131 entries to the Entity List with destinations Russia (63), China (42), Iran (11), Turkey (8), and one each in Canada, Cyprus, Kazakhstan, Kyrgyzstan, Crimea Region of Ukraine, Ukraine, and the United Arab Emirates. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish and other third-country firms (e.g., MAK Logistics, Megatek Ltd., Wellgo International, AllChips Limited, Chipgoo Electronics) named for supplying U.S.-origin electronics and dual-use items to Russian industry and military, plus designation of large numbers of Russian military manufacturers (e.g., JSC 75 Arsenal, FSE Aleksinsky Chemical Plant) as military end users. License requirement is "all items subject to the EAR" with policy/presumption of denial; case-by-case for EAR99 food and medicine to certain Russian military end users. Effective on publication 2024-08-27.

China's Ministry of Commerce and General Administration of Customs jointly issued Announcement No. 33 of 2024 on 15 August 2024, imposing an export licensing regime on antimony ore, antimony metal, antimony oxides (purity ≥99.99%), organic antimony compounds, antimony hydride, indium antimonide, and gold-antimony smelting technology, effective 15 September 2024. The announcement also covers six-sided top-press equipment used in superhard-materials (diamond, cubic boron nitride) production. China accounts for approximately 47% of global antimony mine output and an estimated 75-80% of refined antimony supply; in the months following implementation, Chinese antimony export volumes fell by approximately 97% and global antimony trioxide spot prices roughly doubled.

The U.S. Bureau of Industry and Security (BIS) published a final rule expanding the scope of the Iran Foreign Direct Product (FDP) rule in the Export Administration Regulations (EAR) to implement the "No Technology for Terror Act" (Public Law 118-50, Division N), signed by President Biden on April 24, 2024. The expanded rule extends EAR jurisdiction to additional foreign-produced items destined for Iran — including a broader set of items derived from U.S.-origin technology or software, or produced by plants/components that are themselves direct products of U.S.-origin technology — and requires a BIS license for their export, reexport, or in-country transfer to Iran. The rule also provides specified exclusions from the otherwise-applicable license requirements. The rule became effective on July 23, 2024 (publication July 26, 2024).

BIS final rule (FR Doc 2024-13148, 89 FR 51644, RIN 0694-AJ87) expanding the Export Administration Regulations' Russia and Belarus sanctions architecture. Effective 12 June 2024 (most provisions) and 16 September 2024 (the EAR99 enterprise-software paragraph at §746.8(a)(8)), the rule introduces a new licence requirement for thirteen named categories of EAR99 enterprise software (ERP, CRM, BI, SCM, EDW, CMMS, project management, PLM, BIM, CAD, CAM, ETO) destined for Russia or Belarus; permits address-only Entity List designations to capture high-diversion addresses; adds eight Hong Kong addresses to the Entity List; and refines the Russia/Belarus Industry Sector Sanctions and Foreign Direct Product (FDP) rule. Released the day before the G7 Italy summit alongside coordinated OFAC, State, and Treasury actions that together designated 300+ persons and entities.

Indonesia's Ministry of Trade promulgated Peraturan Menteri Perdagangan (Permendag) No. 10 of 2024 on 30 May 2024, amending Permendag 22/2023 on Goods Prohibited for Export. The regulation set 31 December 2024 as the final cutoff for copper-concentrate and anode-sludge exports — extending the original 1 June 2024 ban deadline by seven months — and enforced a full prohibition starting 1 January 2025. The measure is paired with ESDM Regulation No. 6 of 2024 covering the upstream mining-product side, completing the legal architecture of Indonesia's copper "hilirisasi" (downstream-isation) mandate. The ban forces all domestically mined copper concentrate to be smelted and refined inside Indonesia. Two operators are directly affected: PT Freeport Indonesia (PTFI), majority-owned by state holding MIND ID with Freeport-McMoRan as minority partner, which operates the Grasberg mine in Papua and the new Manyar/Gresik smelter in JIIPE; and PT Amman Mineral Nusa Tenggara (subsidiary of PT Amman Mineral Internasional, IDX:AMMN), which operates the Batu Hijau mine in Sumbawa with a smelter under commissioning. A fire at Freeport's Gresik smelter in October 2024 disrupted ramp-up and forced the government to grant a discretionary export-permit extension into 2025 for PTFI, signalling that the ban — while now legally in force — is being enforced flexibly during smelter commissioning rather than as a hard stop. Permendag 10/2024 is the copper-sector equivalent of the 2020 nickel- ore export ban (ESDM 11/2019) and the planned bauxite-ore ban (effective June 2023). Together these three measures complete Indonesia's resource-nationalism package across its three highest-value mineral exports: nickel, bauxite, and copper. Combined domestic smelter capex commitments tied to the copper rule (Freeport Manyar + Amman Sumbawa) total ~USD 6 billion. Indonesia's Finance Ministry estimated forgone export revenue of ~Rp 10 trillion (~USD 640 million per year) from the copper-concentrate ban alone, which the government is treating as an acceptable downstream-policy cost. Severity is set at 4: the action is binding, durable, and reshapes a globally relevant supply chain (Indonesia is ~5% of global mined copper, rising), but discretionary export extensions during smelter commissioning soften near-term enforcement and limit the immediate market shock relative to the harder 2020 nickel rule.

The US Bureau of Industry and Security (BIS) final rule (89 FR 41706; FR Doc 2024-10485) added 37 entities under 37 entries to the Entity List, all listed under the destination of the People's Republic of China. BIS designated these parties for one or more of three rationales: (i) shipping US-controlled items to Russia in violation of EAR controls, (ii) attempting to acquire US-origin items to support China's military modernisation or quantum-technology capabilities, and (iii) ties to the PRC high-altitude balloon that overflew the United States in late January–early February 2023. The designations span PRC technology companies (predominantly quantum-computing firms), manufacturing companies, and research institutes. License requirement is "all items subject to the EAR" with a policy of presumption of denial and no license exceptions available. The rule is effective 2024-05-09, with publication in the Federal Register on 2024-05-14.

On 2 May 2024 Türkiye's Ministry of Trade announced that all export, import and transit transactions with Israel, covering all product groups, were halted, as the second phase after the 9 April 2024 restriction on 54 product groups. Customs declarations naming Israel as country of shipment, destination or origin are no longer registered. The ministry stated the halt stays in force until Israel declares a ceasefire in Gaza and allows uninterrupted humanitarian aid access.

The Defence Trade Controls Amendment Act 2024 (C2024A00021) received Royal Assent on 8 April 2024 and created three new criminal offences in the Defence Trade Controls Act 2012: section 10A (supply of Defence and Strategic Goods List technology in Australia to a non-exempt foreign person); section 10B (secondary supply of DSGL Part 1 Munitions or Part 2 Dual-Use Sensitive/Very Sensitive goods or technology outside Australia when originally exported from Australia); and section 10C (provision of DSGL Part 1 services to foreign nationals outside Australia). All three offences carry maximum penalties of 10 years imprisonment or 2,500 penalty units (~A$782,500), or both. The offence framework commenced 1 September 2024 with a six-month compliance-transition period; criminal liability attached from 1 March 2025. The Act also codifies AUKUS-partnership exemptions, carving out supplies to and from citizens and permanent residents of the United Kingdom and United States, underpinning the licence-free trilateral technology-transfer environment sought under AUKUS Pillar 2.

The US Bureau of Industry and Security (BIS) final rule (89 FR 14385; FR Doc 2024-03969; Docket 240215-0050; RIN 0694-AJ54) added 93 entities under 95 entries to the Entity List, effective 23 February 2024, with destinations Russia (63), Turkey (16), China (8), UAE (4), Kyrgyzstan (2), India (1), and South Korea (1). The dominant rationale is enforcement of Russia-diversion controls: 46 Russian defense manufacturers are designated as military end users acquiring US-origin items for Russia's armed forces, five Chinese entities (including Dennex Enterprises Limited and Shenzhen Speed Industrial Materials Co.) are cited for facilitating diversion of controlled microelectronics to Russia, and 16 Turkish firms are cited as procurement hubs obtaining US-origin items of importance to Russia's war effort. Four UAE entities are designated for transshipment networks serving both Russia and Iran. All entities are subject to a presumption of denial for EAR-controlled items; Russian military end users are additionally subject to the Russia/Belarus FDP rule (15 CFR 734.9(g)).