Industrial Policy & Trade Monitor· 2665 actions· ✨ 90 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 (BIS) final rule (89 FR 87261; FR Doc 2024-25411) added 40 entities under 42 entries plus four addresses to the Entity List under the destinations China (11), India (5), Malaysia (2), Russia (13), Singapore (1), and Turkey (14), and modified 52 existing entries across China, Estonia, Finland, India, Turkey, the UAE and the UK. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish, Indian, Malaysian and Singaporean entities listed for transshipping controlled US-origin items to Russian defense end users; the 13 Russia entries cover chemical and biological warfare R&D and defense procurement networks. License requirement is "all items subject to the EAR" with a policy/presumption of denial; four China addresses get the narrower "CCL + EAR99 supp. 7" scope. Effective on publication 2024-11-01.

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.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 8 persons to the Unverified List (UVL) and removing 2. Of the 8 additions, 3 are under China, 2 under Germany, 1 under Pakistan, and 2 under Türkiye. Of the 2 removals, 1 is under Saudi Arabia and 1 under China. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 16 October 2024 (89 FR 83428, FR Doc 2024-23638).

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 Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 persons to the Unverified List (UVL) and removing 8. Additions are under five destinations: China (8), Türkiye (2), Cyprus (1), Kyrgyzstan (1), and the United Arab Emirates (1). Removals span China (6), UAE (1) and Russia (1). The single Russian entry (EFO Ltd.) was removed from the UVL because BIS simultaneously moved it to the Entity List, allowing BIS to delete Russia entirely as a UVL destination. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting items subject to the EAR. Published and effective the same day, 3 July 2024 (89 FR 55036, FR Doc 2024-14642).

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.

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)).