NBR Special Report No. 115
Charting China’s Export Controls
Predicting Impacts on Critical U.S. Supply Chains
Building on the NBR report “Critical Technology Supply Chains in the Asia-Pacific” (November 2023), this new report examines China’s existing export control regime and presents a methodology for anticipating future controls on raw materials. It concludes that future export controls will likely focus on critical minerals and specific material processing equipment.
EXECUTIVE SUMMARY
MAIN ARGUMENT
The PRC’s export control regime has grown and formalized in recent years in response to an increasingly active and complex landscape of U.S. and allied export controls. The PRC’s system of export controls has historically been piecemeal, and its administration poorly understood. Recent formalization of the system beginning in 2020 and escalating in 2023 is consistent with the PRC’s increased exercise of lawfare and demonstrates greater regulatory capabilities. PRC authorities are able to weaponize supply chains by targeting specific critical minerals under new export controls.
POLICY IMPLICATIONS
- The PRC has gradually implemented and formalized export control measures, partly mirroring existing international frameworks. The country is relying further on a combination of these export controls and new legal mechanisms to retaliate against U.S. and allied technology protection measures.
- The PRC’s use and calibration of retaliatory tools is dependent on several factors that can be subject to change, including the PRC’s perception of U.S. goals and priorities.
- Continuous analysis of trade and investment data can provide some guidance and allow for government and business preparation ahead of anticipated changes in export controls in both the U.S. and China.
Emma M. Rafaelof is a Research Analyst at Pacific Northwest National Laboratory.
Taylore A. Roth is a Research Analyst at Pacific Northwest National Laboratory. She is also a Nonresident Fellow at NBR.
Mykael SooTho is a Physicist at Pacific Northwest National Laboratory.
John VerWey is an Advisor at Pacific Northwest National Laboratory. He is also a Nonresident Fellow at NBR.