China's export control regulations for dual-use items officially came into effect on December 1, accompanied by the implementation of an export control list detailing these items.

Dual-use items refer to goods, technologies and services that serve both civilian and military purposes, particularly those that might help enhance military capabilities. This includes their potential use in the design, development, production or deployment of weapons of mass destruction or their delivery systems. China's export control list for dual-use items comprises 10 industry categories, including specialty materials, chemicals, electronics, computers, sensors and lasers, and aerospace.

Two days later, the Ministry of Commerce (MOFCOM) announced tighter export controls on dual-use items to the United States. The new rules prohibit exports of dual-use items intended for U.S. military users or purposes. Additionally, exports of items related to gallium, germanium, antimony, and superhard materials to the U.S. are, in principle, banned. For graphite-related dual-use items, exports are now subject to stricter reviews focusing on the end-user and intended use.

MOFCOM further stated that organizations or individuals from any country or region found transferring or providing China-origin dual-use items to the U.S. in violation of these provisions will face legal consequences.

It is common practice internationally to impose export controls on dual-use goods, technologies and services. However, China has specific reasons for introducing controls on these exports to the U.S. shortly after the related regulations took effect.

The U.S. Government's efforts to contain and suppress China have strained the foundation of friendly cooperation between the two countries, prompting the Chinese Government to take necessary countermeasures. Recent U.S. actions included a series of semiconductor export restrictions targeting China and the approval of a $1.99-billion arms deal with Taiwan Province, which features advanced equipment such as the NASAMS air defense system and the Sentinel radar system.

In response to these actions, which disregard China's opposition and undermine shared interests, China has implemented a "reciprocal response." The new export controls on dual-use items are both a countermeasure and a necessary step. Materials such as gallium, germanium and antimony, which are critical in the semiconductor, aerospace and military industries, are of great strategic value.

China's export control on dual-use items to the U.S. underlines its strong opposition to unilateralism and hegemony. In recent years, the U.S. has broadened the concept of national security, politicized and weaponized economic, trade, and technological issues, and misused export control measures.

The U.S. has arbitrarily restricted exports of certain products to China and placed multiple Chinese companies on sanction lists to suppress and contain China. These actions have seriously undermined international trade rules, violated the legitimate rights and interests of enterprises, and destabilized global industrial and supply chains. In response to Washington's unilateralism and hegemonism, which threaten globalization, China has taken firm action. This approach sends a clear message to U.S. politicians: Unilateralism and hegemonism are not sustainable in a globalized world.

Will the export controls on dual-use items affect normal trade, scientific and technological exchanges, or economic cooperation? The answer is no. Export controls do not equate to a complete ban on exports. Under the regulations for dual-use item controls, China will ensure effective management while simultaneously fostering a stable, transparent and predictable institutional framework to support the compliant trade of such items.

Commenting on the measures, a MOFCOM spokesperson reiterated that the Chinese Government remains firmly committed to advancing high-level opening up and strongly opposes the misuse of national security concerns to justify unjust trade restrictions.

China is also open to strengthening dialogue with relevant countries and regions on export controls, aiming to collaboratively promote the security and stability of global industrial and supply chains.

Copyedited by Elsbeth van Paridon 

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