What Foreign Businesses Need to Know about China’s Recent Strengthened Enforcement of Export Controls and Countermeasures

Jianwei (Jerry) Fang, Rui Yang, Ke Dong, Songyang Wang, Jiaying Jiang and Yongan Shen of Zhong Lun Law Firm analyze China’s latest strengthened enforcement in export control and countermeasure actions. The authors examine how newly-announced restrictions and countermeasures reflect China’s strategy of reciprocal regulatory response, the expansion of its extraterritorial jurisdiction through origin-based control mechanisms, and the increasing compliance challenges for foreign businesses operating in or with China

Summary


  • In September and October 2025, China introduced a new round of export controls and countermeasures targeting key strategic sectors and foreign entities
  • According to announcements from two regulators, China

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