China: Export Controls & Trade & Investment Sanctions

China has tightened export controls on rare earths. In April 2025, China's Ministry of Commerce (MOFCOM) and General Administration of Customs (GACC) issued announcements to regulate 7 categories of medium and heavy rare earths (MHREs) by clarifying their control codes, HS codes and scope of control.

In recent years, international developments such as the US-China trade tensions and the Russia-Ukraine conflict have led to the expansion of economic sanctions, directly impacting numerous cross-border transactions and contract performance.

On Dec. 10, 2024, the State Administration for Market Regulation released the Guidelines for the Review of Horizontal Business Concentrations (Guidelines).