Emma M. Rafaelof, Taylore Roth, Mykael SooTho, and John VerWey
In December 2024 the People’s Republic of China (PRC) announced an outright ban of gallium, germanium, and antimony exports to the United States.1 The prohibition followed U.S. controls to stem the PRC’s development of advanced semiconductors, with both actions representing a significant escalation in U.S.-China trade tensions. Steady adjustments to PRC export control regulations and legal mechanisms over the last few years have diversified the country’s toolkit for engaging in strategic competition with the United States. The December 2024 ban was the next level of escalation from a July 2023 announcement that first developed controls on gallium and germanium. While U.S. export controls limiting PRC access to semiconductors have received substantial coverage in recent years, this action to unilaterally control several relatively obscure materials initially received limited attention. However, PRC controls on these critical materials, which are used in everything from wind turbine magnets to semiconductors, were followed later in the year by additional controls on high-end graphite and rare earth element permanent magnet manufacturing technologies. Notably, since PRC export controls on gallium were announced in July 2023, there have been zero recorded PRC-origin exports to any firm in the United States or the Netherlands, according to trade data available in September 2024.
U.S. and allied export control actions restricting PRC access to semiconductor technologies have raised the ire of PRC policymakers, and these seemingly retaliatory actions raise the possibility of future tit-for-tat exchanges. Taken together, changes in PRC export controls throughout 2023 represent a noteworthy shift in the country’s economic statecraft: for the first time, the PRC government systematically employed its formal export control system to retaliate in response to U.S. and partner export controls it deems “unfair.”
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