Since the enactment of the Export Control Law of the People’s Republic of China in 2020, the Chinese government has steadily tightened controls over strategic materials as part of a broader effort to safeguard national security and state interests.  With the implementation of the Regulations on the Export Control of Dual-Use Items on December 1, 2024, followed by the comprehensive revision of the Foreign Trade Law on December 28, 2025, China has completed the legal foundation for what can be described as comprehensive "trade retaliation," extending beyond the scope of conventional export administration.

Against this backdrop, on January 6, 2026, China’s Ministry of Commerce (MOFCOM) and the General Administration of Customs (GACC) implemented stringent measures effectively banning the export of all dual-use items destined for Japan.  This marks the first instance of China applying comprehensive export controls targeting a specific nation, signaling a shift toward the use of its export control regime as an instrument of economic statecraft.

This newsletter provides an in-depth analysis of China’s export control legal framework and the key controlled items affecting global supply chains.  Furthermore, it examines the implications of the recently enacted sanctions against Japan and offer detailed risk mitigation strategies for non-Chinese enterprises operating within the ecosystem.

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