China’s Export Control Pivot Extends Beyond Washington

On October 9, 2025, China’s Ministry of Commerce expanded its export control list to include five additional rare earth elements, while asserting unprecedented authority to monitor the global use of products containing Chinese materials. This move arrived just five days after Beijing blocked a Dutch-owned chipmaker from supplying transistors to European automakers. While the first action followed ongoing tariff disputes with Washington, the second stemmed from governance friction with The Hague.

Beijing’s regulatory infrastructure has undergone a rapid transformation since 2020. Previously reliant on a fragmented patchwork of ministerial rules, China consolidated its approach through the 2020 Export Control Law and the Unreliable Entity List. The subsequent addition of the 2021 Anti-Foreign Sanctions Law and the 2024 Regulations on Export Control of Dual-Use Items replaced ad-hoc political interventions with a procedural framework. These mechanisms, originally modeled on American precedents to address specific bilateral tensions, now provide a flexible legal basis for restricting supply chains across international markets.