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China to Keep Using Export Controls as Retaliation Tool, US Panel Hears

China, which has imposed export controls on critical minerals in recent years to retaliate against foreign trade restrictions, is expected to continue doing so, a researcher told the congressionally mandated U.S.-China Economic and Security Review Commission April 24.

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China’s dominance in critical minerals makes export controls an effective tool for Beijing, said Cory Combs, associate director for climate, energy and industrial policy at advisory firm Trivium China. While China continues using tariffs and sanctions as well, tariffs tend to be more effective from the U.S. side because the U.S. imports far more from China than China imports from the U.S. Sanctions on U.S. defense contractors have little impact.

Export controls on critical minerals “provide Chinese policymakers a rare degree of asymmetrical leverage,” Combs said in written testimony. “They are highly effective at causing material risks and impacts for the U.S. and other offending actors with comparatively little domestic harm from their implementation.”

China’s latest export control action came April 4 when it imposed export restrictions on seven rare earth elements as part of its response to U.S. tariffs (see 2504040024).

China, which implemented its first export control law in 2020, seems to be getting faster at implementing such restrictions, Combs said. “Early export controls saw longer delays between trigger and retaliation, as the policy infrastructure and customs enforcement both took time to develop,” he said. “However, recent controls -- likely prepared in advance, ready for appropriate triggers, and streamlined by unified regulations in late 2024 -- would come in as little as one to two days.”