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

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.

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.

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.

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.

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 (MOFCOM) and General Administration of Customs (GAC) jointly issued Announcement No. 58 of 2025 on 9 October 2025, adding high-energy-density lithium-ion batteries (cells and packs, >=300 Wh/kg), artificial graphite anode materials, related production equipment, and key manufacturing technologies to the dual-use export control list under licence requirement. The controls were scheduled to take effect 8 November 2025 but were suspended the day before via Announcement No. 70 (2025), which deferred entry-into-force until 10 November 2026 in the context of the US-China Busan economic-trade arrangement. Controls remain legislatively adopted and will become operative unless the suspension is renewed or withdrawn.

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), 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 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).

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.

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.

MOFCOM and the General Administration of Customs jointly issued Announcement No. 10 [2025] on 4 February 2025, imposing dual-use export-licence controls on items related to tungsten, tellurium, bismuth, molybdenum and indium under the Export Control Law and Dual-Use Items Export Control Regulations. The controls cover metals, alloys, powders, compounds and related processing technologies across roughly 25 listed item categories (41 HS 10-digit codes). The measure is global in scope but was issued the same day China announced 10-15% retaliatory tariffs on US LNG, coal, crude and farm equipment in response to the Trump administration's 10% fentanyl-tariff hike — extending the MOFCOM critical-minerals control regime beyond gallium/germanium/graphite/antimony/heavy-REEs.

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.