Rapid Changes in Export Controls for Critical Minerals
24 February 2025
The semiconductor industry is a battleground in international trade and geopolitics, with official announcements coming thick and fast in the last two months, from different nations.
The new Trump administration’s stunning announcement (and then delay) of new 25% punitive tariffs against its allies Canada and Mexico, as well as additional 10% tariffs across-the-board on all Chinese imports, caught the world’s attention, including many people with little interest in global trade news. The China tariffs came into effect on 4 February, and China hit back with more targeted tariffs against imports of US coal, liquefied natural gas, crude oil, pick-up trucks, some sports cars and agricultural machinery.
But these come in the context of long-term trade tensions between the US and China, which in December added to export controls for the critical minerals gallium (used to produce the semiconductor chips used in Apple’s iPhones, 5G communications, and radar technologies) and geranium (used in smart phones), plus new restrictions on exports antimony (a “hard metal” used in weapons production). In January, China further restricted exports of tungsten, indium, bismuth, tellurium and molybdenum – also critical minerals. Not long after, the US president voiced his interest in obtaining mineral reserves located in Greenland and Ukraine.
On 15 January, the Dutch government said that it will expand the range of its export controls on advanced semiconductor equipment from 1 April. The controls will now include measuring and inspection equipment used in semiconductor production. The Netherlands is home to a number of major companies in the semiconductor industry, including ASML, NXP and STMicroelectronics.
The Dutch minister for foreign trade and development Reinette Klever said “We believe it is important to maintain control over who gains possession of what technology. The government closely monitors semiconductor manufacturing technology. Technological developments may make it necessary to modify the rules. We are observing increased security risks associated with the uncontrolled export of this specific equipment. For this reason, an export authorisation will henceforth be required.”
A couple of weeks later, Japan moved to expand its list of semiconductor export controls, so that from the end of May it will include cutting-edge chips and quantum computer-related technology (such as lithography equipment and cryocoolers). Exporters will need licenses in order to ensure these goods are not used in weapons or weapons development, said Japanese officials. It also blacklisted 42 more Chinese companies to stop them obtaining dual-use goods, taking the total to 110. China has responded by warning that these steps will have a negative impact on bilaterial trade.
Some advanced manufacturers in Japan have been suggesting that absolute compliance with mineral export controls is practically impossible would be impossible, because supply chains for electronics are so complex, and the identity of the end user cannot be known with certainty. However, export controls are taken very seriously by governments, and non-compliance (whether intentional or not) can have huge consequences for companies.
Contact us for advice about export controls, dual-use goods, customs clearance and how to calculate import costs.
Follow Chamber International on Twitter @ChamberInt and on Facebook for the latest in international trade.
