Industrial Policy & Trade Monitor· 2665 actions· ✨ 90 recent

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.

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.