Industrial Policy & Trade Monitor· 2666 actions· ✨ 89 recent

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 Bureau of Industry and Security (BIS) issued a final rule (FR Doc 2024-08622; Docket 240417-0112; 89 FR 30119) amending the Export Administration Regulations (EAR) to expand the product scope of two Foreign Direct Product (FDP) rules — the Iran FDP rule and the Russia/Belarus/Temporarily occupied Crimea region of Ukraine FDP rule in 15 CFR 734.9(f) — to cover the entirety of the Common High Priority List (CHPL), an HTS-6 list developed jointly with the EU, Japan and the UK that identifies items used in Russian weapons production. The CHPL scope adds basic commercial-grade microelectronics (integrated circuits, RF transceiver modules), test/manufacturing equipment for electronic components, and CNC machine tools to the perimeter, requiring a BIS licence when these foreign-produced items are exported, reexported or transferred to Iran, Russia, Belarus or occupied Crimea. The rule was issued in response to Iran's 13 April 2024 attack on Israel and Iran's ongoing military support for the Russian war in Ukraine; it became effective 18 April 2024 (Federal Register publication 22 April 2024) with a transit grace period for in-flight shipments until 20 May 2024.

On 9 April 2024, Türkiye's Ministry of Trade restricted exports of 1,019 tariff lines across 54 product groups to Israel — including cement, marble, sulphur, aluminium wire, ceramics, varnishes and mineral fertilisers — in response to Israel's conduct of the Gaza war and its refusal of a Turkish request to participate in aid airdrops. The government stated the restriction would remain in force until Israel declared an immediate ceasefire and allowed unimpeded humanitarian aid into Gaza. The measure was superseded three weeks later, on 2 May 2024, when the Ministry halted all exports, imports and transit trade with Israel across every product category.

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)).