How China’s Semiconductor Export Rules Might Affect the Industry Chain (AI Translation)
Listen to the full version

文|财新周刊 卢羽桐 杜知航 覃敏
By Caixin Weekly‘s Lu Yutong, Du Zhihang, Qin Min
随着美国总统换届日临近,中美双方在科技和经贸领域的对战性动作也愈发密集。尤其在美国频繁加码对华半导体出口管制的局面之下,中国商务部也对美国企业祭出了史上最严的金属出口管制。
As the inauguration day for the new U.S. president approaches, the confrontations between China and the U.S. in the realms of technology and trade have become increasingly frequent. Especially amid the situation where the U.S. continually intensifies semiconductor export controls against China, China’s Ministry of Commerce has, in turn, imposed the most stringent metal export restrictions in history on American companies.
2025年第一个工作日,中国商务部产业安全与进出口管制局宣布将通用动力公司等28家美国实体列入出口管制管控名单,禁止向它们出口军民两用物项。这是2024年10月《两用物项出口管制条例》发布以来,首个公开发布的出口管制管控清单。
On the first working day of 2025, China's Ministry of Commerce's Bureau of Industry Security and Export Control announced the inclusion of General Dynamics and 27 other U.S. entities on an export control list, prohibiting the export of dual-use items to them. This marks the first publicly released export control list since the October 2024 publication of the "Dual-Use Items Export Control Regulations."
一个月前的2024年12月3日,中国商务部已宣布原则上不予许可镓、锗、锑、超硬材料相关两用物项对美国出口;对石墨两用物项对美国出口,实施更严格的最终用户和最终用途审查。这是中国首次明确针对美国在关键矿产出口层面进行限制,不允许任何形式的转出口至美国;相较以往相关政策给出一个月的缓冲期,此次政策即日生效。
On December 3, 2024, a month ago, China's Ministry of Commerce announced a principled decision not to permit the export of items related to gallium, germanium, antimony, and superhard materials to the United States. For dual-use graphite exports to the U.S., stricter end-user and end-use reviews will be implemented. This marks the first time China has imposed explicit restrictions on the export of critical minerals to the U.S., prohibiting any form of re-export to the country. Unlike previous policies that allowed for a one-month grace period, this policy took effect immediately.
- DIGEST HUB
- As tensions rise between China and the U.S., both countries have implemented stringent export controls on semiconductors and critical minerals, like gallium, germanium, and antimony.
- China's new export restrictions, aimed at the U.S., have led to surging prices for these minerals, which are essential for semiconductor production and the military.
- The U.S. and its allies are seeking alternative supplies to mitigate the impact, but China's dominance in these markets challenges easy substitution.
As the new U.S. president prepares to assume office, tensions between China and the U.S. have intensified, particularly concerning technology and trade. A key aspect of these tensions is the U.S. tightening semiconductor export controls against China, to which China has responded by imposing the strictest metal export restrictions on American entities in history. Recently, China's Ministry of Commerce listed entities like General Dynamics, introducing a ban on significant materials such as gallium, germanium, and antimony. This is China's first explicit restriction on critical minerals to the U.S., underscored by a sharp price rise in these metals. [para. 1][para. 3] Company responses and market adaptations vary. The U.S.-China trade war has triggered significant reactions in the global metal market, spurring notable increases in the prices of germanium and antimony. These shifts reflect the tensions governing this titanic rivalry. [para. 5]
Gallium, germanium, and antimony are crucial to the global supply chain, with China dominating production. China provided 98% of the global gallium supply and significant portions of germanium and antimony in 2023. Gallium's price jumped by 15.4% within a month, whereas germanium and antimony prices rose moderately. This strategic move disrupts the supply chains vital to U.S. industries, including semiconductor and military sectors, where these metals are foundational for high-tech applications. [para. 5][para. 6][para. 8] Aware of the vital role these metals play, the U.S. predicts a $3.4 billion GDP decrease should China institute a full export ban. This prediction indicates the severe economic ramifications that could ensue if the situation escalates.[para. 7]
By controlling these resource exports, China is leveraging its dominant position in the global supply chain to counteract U.S. semiconductor restrictions first imposed in 2022. An imbalance in the semiconductor industry is evident as the tighter U.S. export controls create hurdles, supposedly aiming to stymie China's AI and supercomputer advancement. [para. 10][para. 12] China had previously announced restrictions on gallium and germanium in 2023 under the guise of safeguarding its national security, a move that alarmed the global semiconductor sector already consuming its vast production resources.[para. 15]
International reactions to China's export bans have been swift. Countries reliant on China's semiconductor and mineral supplies fear disruptions as they seek alternatives to address this evolving geopolitical issue. [para. 3][para. 24] China is fortifying its strategic resource policies with its Ministry of Commerce highlighting dual-use materials that blend military and civilian applications, citing responsibilities to international norms while addressing national security. Multiple efforts are centered around gaining strategic advantages and controlling the global technological landscape. [para. 6][para. 21]
Ongoing concerns about the broader implications loom, with future adjustments anticipated as China could potentially extend similar controls to other critical resources like rare earths and tungsten. Tungsten, guaranteeing high-performance industrial and defense applications, notably holds strategic value with China providing 80% of global supply. The U.S. is already looking for ways to diversify its resource channels, with countries like Canada serving as alternative sources following Chinese tightening restrictions. [para. 25][para. 28][para. 33]
The global market thus stands at a crossroads amid these ongoing trade tensions. International buyers like Japan and the EU remain cautious, assessing available options as geopolitical dynamics shift, all while navigating existing supply chains and potential new technological routes. The U.S. and allied countries rush to establish alternative supply chains outside of China's grasp, further complicating global technological dependencies and trade partnerships. [para. 5][para. 15][para. 35]
- General Dynamics
通用动力公司 - General Dynamics is one of the 28 U.S. entities that the Chinese Ministry of Commerce has added to its export control list. This action prohibits the export of dual-use items to these entities, highlighting escalating tensions between the U.S. and China in technology and trade sectors.
- Aluminum Corporation of China
中国铝业 - Aluminum Corporation of China, known as Chinalco, is one of the major metal suppliers involved in the production of gallium, germanium, and antimony. These are byproduct metals, and the company plays a significant role in their supply chain. Due to the limited market scale of these byproduct metals, any impact on export would have a limited effect on Chinalco's main business operations.
- Tibet Huayu Mining
华钰矿业 - Tibet Huayu Mining is mentioned as one of the major suppliers of gallium, germanium, and antimony in China. These metals are co-products of major metals like lead and zinc, and Tibet Huayu Mining, along with other large metal enterprises, plays a significant role in the supply of these critical materials.
- Yunnan Germanium
云南锗业 - Yunnan Germanium is one of the large metal enterprises in China supplying germanium and other minor metals like gallium and antimony. Despite the limited market size of these by-products, reduced exports would have minimal impact on their main business lines. The company has recently increased export prices for germanium products.
- Huanghe Whirlwind
黄河旋风 - Huanghe Whirlwind is mentioned as a company that plans to increase prices for diamond-related products starting in 2025, following China's export restrictions on key minerals. The company is likely adjusting its pricing strategy due to market changes induced by these export controls.
- Rio Tinto
力拓集团 - Rio Tinto is evaluating the potential to extract and utilize gallium at its alumina plant in Canada. After completing the initial technical development phase, the company plans to construct a demonstration plant with a potential production capacity of up to 3.5 tons of gallium annually. The Quebec government has pledged up to 7 million Canadian dollars to support this phase. The project aims to strengthen the supply chain for critical minerals in North America.
- US Antimony Corporation
美国锑业 - US Antimony Corporation has accelerated international supply contract negotiations for antimony ore following China's export restrictions. The company is sourcing antimony from Australia and Thailand and supplying it to its smelting plant in Mexico. This move comes after restarting its Mexican operations, which had been shut down in March 2024 due to losses. The first shipment is expected in March 2025.
- POSCO
浦项制铁 - POSCO, a South Korean company, has reached an agreement with Australia's Black Rock Mining (BRM) to develop a natural graphite supply chain. This collaboration focuses on supporting the development of a graphite mine in Tanzania, a project pursued under the Mineral Security Partnership (MSP) initiative aimed at strengthening the supply chain for critical minerals.
- Henkel
汉高公司 - Henkel, a German company, informed its customers in November 2024 that due to delays in antimony imports awaiting Chinese approval, it would suspend deliveries of four types of adhesives and lubricants widely used by automakers.
- Before July 2023:
- China generally exported gallium, germanium, and antimony without requiring a license.
- July 2023:
- China's Ministry of Commerce and the General Administration of Customs announced export controls on gallium and germanium.
- October 2023:
- The U.S. upgraded its semiconductor export restrictions against China.
- August 2024:
- China imposed export controls on certain antimony and super-hard material-related items.
- December 2, 2024:
- The U.S. Department of Commerce's BIS announced new export restrictions on 136 Chinese entities and semiconductor-related items.
- December 3, 2024:
- China announced restrictions on the export of gallium, germanium, antimony, and superhard materials to the United States.
- By January 7, 2025:
- Prices of germanium and antimony surged to record highs.
- January 16, 2025:
- A spokesperson for China's Ministry of Commerce stated China's stance on export controls for dual-use items related to strategic resources.
- PODCAST
- MOST POPULAR



