Trade Laws and Restrictions | Timeline and Implications

China’s latest export restrictions on critical metals—including gallium, germanium, antimony, titanium, tungsten, lithium, molybdenum, and indium—have significantly disrupted global supply chains, particularly in the U.S. and Europe. These measures, implemented in mid-2023, December 2024 and early 2025, reflect China’s strategic response to ongoing trade tensions, especially with the U.S. In an era of heightened geopolitical uncertainty and supply chain disruptions, it is crucial for companies reliant on critical minerals to proactively understand and secure alternative supply sources.

October 2022: The U.S. Announces Exports Restrictions on Semiconductors to China

This set of export controls restricts US companies from exporting advanced semiconductors to China. These items and capabilities are used by China to produce advanced military systems, improve the speed and accuracy of its military decision making, planning, and logistics, as well as of its autonomous military systems.

These restrictions were issued as a way of protecting U.S. national security and foreign policy interests. The end goal is to restrict China to purchase and manufacture of high-end chips used in military applications.

July 2023: China Announces Export Licensing Measures on Gallium and Germanium

Gallium is a critical and strategic component in the US Department of Defence supply chain. It has properties that allow power amplification and secured communication, and is widely used in radar systems and advanced microelectronics, also making it essential for civil applications such as 5G infrastructure. In July 2023, China introduced export licensing measures requiring Chinese exporters to report foreign end users of gallium and germanium. The Ministry of Commerce mandated that exporters secure authorisation to align with China’s national security objectives. These measures were designed to ensure that strategic materials critical to defence and technology sectors remained under strict government control. This is widely viewed as a direct response to the 2022 export restrictions issued by the U.S.

Similarly, China has implemented an export restriction on germanium shipments to the U.S.

European importers are experiencing difficulties in securing supplies of both gallium and germanium, facing uncertainty as China is actively working to prevent gallium and germanium indirectly reaching the U.S. through Europe. Additionally, Chinese exporters are experiencing prolonged processing times, as authorities impose stringent scrutiny to ensure absolute control over material destinations.

China produces 90 percent of the world’s gallium and 60 percent of the world’s germanium.

October 2023: China Issues Export Restrictions on Graphite

China is the top exporter of graphite and refines more than 90% the world’s graphite. China requires export permits and exporters to disclose the end-users of exported graphite. The reason behind this restriction is to safeguard China’s national security and interests. According to Chinese customs data, this restriction is not targeted to one specific country but at the top buyers of graphite from China, which includes Japan, the U.S., India, and South Korea. With rising sales of electric vehicles, American and European automakers must ensure that they are able to source outside of China.

August 2024: Export Restrictions on Antimony

China announced restrictions on antimony exports, effective September 15, 2024. The measure mandated that entities exporting antimony-related products, including ore, metals, and oxides, obtain a license from China’s Ministry of Commerce. Antimony is a key material in flame retardants, photovoltaics, night vision goggles, and ammunition. The supply chain impact was immediate, with global prices surging by over 200% in 2024, and speculation that prices could reach $40,000 per tonne in the first half of 2025.

With China responsible for nearly 50% of global mined antimony production, the market is seeking alternative sources. As demand for antimony grows, particularly in electric vehicle (EV) batteries, securing a stable supply is increasingly urgent.

December 2024: U.S. Strengthens its Semiconductor Export Restrictions

The Biden Administration imposed a comprehensive set of restrictions on China’s semiconductor industry, aiming to curb its technological advancements. The measures included placing 140 entities, primarily Chinese semiconductor manufacturers and investment firms, but also companies from Japan and Singapore, on the Entity List. Most U.S. exports subject to the Export Administration Control (EAR) were prohibited from reaching these entities.

Export controls included High-Bandwidth Memory (HBM), a critical component for artificial intelligence (AI) model training. Without access to HBM, leading Chinese tech companies have faced difficulties in developing and advancing AI technologies, weakening China’s semiconductor industry.

December 2024: China’s Retaliatory Measures on Gallium, Germanium, and Antimony

In direct response to the U.S. semiconductor restrictions, China imposed a full export ban on gallium, germanium and antimony shipments to the U.S. These restrictions enforced the existing restrictions requiring licensing measures, although this time it escalated to an outright ban of exports of gallium, germanium, and antimony. This ban is also country specific, directly targeting the U.S.

The 2023 restrictions were a global, procedural tightening of gallium and germanium exports, aimed at flexing China’s muscle in the trade war. The December 2024 ban is a U.S.-specific prohibition that expands to additional materials, reflecting a more confrontational stance tied to U.S. actions. The shift from licensing to an outright ban, and from a global to a targeted approach marks a significant escalation in both scope and intent.

February 2025: Export Licensing Measures on Tungsten

China produces over 80% of the world’s tungsten and remains its largest consumer. The 18 authorised Chinese tungsten export companies primarily supply Japan and South Korea, which then process tungsten components for U.S. industries. While the U.S. sources tungsten primarily from Canada, it remains indirectly dependent on China’s tungsten supply chain.

In February 2025, China implemented licensing requirements on tungsten, alongside tellurium, bismuth, molybdenum, indium, and other rare earth elements. Exporting companies must apply for a license for each shipment and clarify the foreign end user of the exported material.

China introduced additional export restrictions on molybdenum and indium, classifying both as dual-use materials. These measures require licensing for exports and mandate detailed reporting on foreign recipients. The new controls apply not only to raw and processed materials but also to technology and information related to their applications.

Molybdenum, essential for high-strength steel alloys, is widely used in the aerospace, defence, and energy industries. China accounts for nearly half of global molybdenum production. Indium, used in semiconductors and display technologies, is primarily refined in China which controls about two-thirds of global production. The new export controls are expected to cause significant supply chain disruptions, leading to material shortages and rising costs for industries reliant on these critical metals.

Potential Future Restrictions on Lithium and Titanium

China has signalled possible licensing measures for sorbents, a key filtration technology used in lithium extraction from brine—the most common production method in Chile. If enacted, these restrictions could limit access to crucial lithium extraction technology, strengthening China’s dominance in global battery production. The move would seek to secure China’s high market share in lithium production and prioritise production for Chinese domestic battery supply chains.

As of now, China has not officially imposed export restrictions or bans on titanium. However, there is growing speculation that such measures may be forthcoming, given China’s recent actions to control exports of other critical minerals. China is the world’s largest producer of titanium ore. Market commentators have raised the potential for China’s moves in the current trade war with the US to include exports of titanium sponge. China’s nine major titanium producers produced 218,000t in 2023, a 25% increase over 2022. China has enacted a comprehensive strategy to compete with Airbus and Boeing, and domestically, China is forecast to be the largest market for civil aircraft through 2045, led by COMAC. The US Department of Defence included COMAC on its list of Chinese military companies in January 2025, complicating COMAC’s path to global certification.

Conclusion

The escalating tit-for-tat export restrictions between the U.S. and China, spanning semiconductors, critical minerals, and rare earth elements, signal a deepening geopolitical and economic rivalry with far-reaching consequences. From the U.S.’s initial semiconductor export controls in 2022 to China’s retaliatory bans on gallium, germanium, and antimony by December 2024, and the looming potential restrictions on lithium and titanium, both nations are weaponising their dominance over strategic resources. These measures have disrupted global supply chains, driven up costs, and forced industries to scramble for alternatives. China’s shift from procedural licensing to targeted bans, coupled with the U.S.’s broadening Entity List, reflects an intensifying trade war that shows no signs of abating. As of February 2025, the addition of tungsten, molybdenum, and indium to China’s export controls underscores the stakes: control over the materials and technologies that power modern economies. Looking ahead, the potential inclusion of lithium and titanium restrictions could further entrench China’s leverage in battery and aerospace sectors, while the U.S. pushes to decouple its supply chains, with a significant recent interest towards the mineral wealth of Canada, Greenland, and Ukraine. This cycle of retaliation risks fracturing global trade and challenging industries worldwide to adapt to an era of resource protectionism.

TDi Sustainability has an expertise in dealing with such uncertainties and helping companies to become as resilient as possible through risk identification and analysis, supply chain mapping and data tools that enable navigation of the evolving geopolitical landscape. We deliver tailored practical risk management solutions that ensure long-term sustainability in an unpredictable global market. With our deep expertise in strategic sourcing and supply chain risk management, we can help to guide companies on the best way forward for responsible and resilient sourcing against the background of the escalating US-China trade war.