/>iThis summary helps to navigate the various retaliation actions China has taken in the past 50 days after President Trump took office on January 20, 2025, to counter the US trade restrictions, including (i) imposing additional tariff on certain US origin products, (ii) adding 12 US companies to the Unreliable Entity List, (iii) control of export of certain precious minerals, (iv) adding 15 US companies to the export control related Controlled Party List and (v) launching anti-circumvention investigation against US fiber optic products.
1. Tarriffs
The following additional tariffs has been imposed on US origin products:
| Effective Date | Tariffs on Goods Originated from the US |
| February 10, 2025 | 15% on coal and liquefied natural gas10% tariff on crude oil, agricultural machinery, large-displacement cars, and pickup trucks No reduction or exemption. |
| March 10, 2025 | 15% on chicken, wheat, corn and cotton10% on sorghum, soybeans, pork, beef, aquatic products, fruits, vegetables and dairy products No reduction or exemption. *Goods that were departed before March 10, 2025, and imported between March 10, 2025 and April 12, 2025 are not subject to the additional tariffs. |
2. Unreliable Entity List
The Unreliable Entity List (UEL) is a blacklist administrated by the China Ministry of Commerce (MOFCOM) pursuant to the Regulation on Unreliable Entity List. Companies placed on the UEL may be subject to the following measures:
- Restricted or prohibited from import or export from China
- Restricted or prohibited from investing in China
- Restricted or prohibited from entering into China
- Its personnel may be denied of work permits or residency permits
- Be imposed with a fine
Since January 20, 2025, China has added 12 companies to the UEL with the list and the applicable restriction as follows.
| Effective Date | Unreliable Entity List | Restrictive Measures |
| February 4, 2025 | PVH group* lllumina, Inc. Reasons of Addition – Discriminatory actions against Chinese companies. Termination of normal business with Chinese companies. *As previously reported, MOFCOM launched an investigation against PVH likely in connection with UFLPA. See our previous post. PVH Facing the Risk of Being Placed on China’s Unreliable Entities List | The Trade Practitioner | PVH – Specific restrictive measures to be announced. Illumina – Prohibited its exporting of gene sequencers to China. |
| March 4, 2025 | TCOM, Limited PartnershipStick Rudder Enterprises LLCTeledyne Brown Engineering, Inc.Huntington Ingalls Industries Inc.S3 AeroDefenseCubic CorporationTextOreACT1 FederalExoveraPlanate Management Group. Reasons of addition were not announced. | Prohibited from import and export with China Prohibited from making new investment in China |
3. Export Control of Certain Minerals
On March 4, 2025, MOFCOM released an announcement (10th Announcement) to control certain products relating to tungsten, tellurium, bismuth, molybdenum and indium. The 10th Announcement also updates and supplements the Dual-Use Items Control List that was published December 2024.
To facilitate businesses in making classification and assessment of products, the 10th Announcement includes the HS code of each item under control.
For more information about China’s dual-use control and control list, please refer to our previous article: China Releases Consolidated Dual – Use Items Control List | Publications | Insights & Events | Squire Patton Boggs.
4. Controlled Party List (管控名单)
The Controlled Party List (CPL) was first created under the Export Control Law and supplemented under the new Regulations on the Export Control of Dual Use Items that took effect on December 1, 2024. Companies on ECPL are not allowed to purchase any controlled items without a special approval from MOFCOM.
For more information about Controlled Party List, please refer to our previous article: China Released the First Comprehensive Dual-use Items Export Control Regulations | Publications | Insights & Events | Squire Patton Boggs
On March 4, 2025, MOFCOM, for the first time, used the tool of ECPL and added 15 companies to ECPL.
| Effective Date | Controlled Party List | Restrictive Measures |
| March 4, 2025 | LeidosGibbs&Cox, Inc.IP Video Market Info, Inc.Sourcemap, Inc.Skydio, Inc.Rapid Flight LLCRed Six SolutionsShield AI, Inc.HavocAINeros TechnologiesGroup WAerkomm Inc.General Atomics Aeronautical Systems, Inc.General Dynamics Land SystemsAero Vironment Reasons of Addition – Protect national security and interest, perform non-proliferation and other international obligations. | Export of dual-use items to the listed companies are prohibited All ongoing export must be stopped immediately If export is necessary under special circumstances, the exporter shall make an application to MOFCOM |
5. Anti-circumvention Investigation
On March 4, 2024, MOFCOM announced an anti-circumvention investigation into certain cut-off shifted single-mode optical fiber, marking the first time that China has initiated such an investigation.
The investigation was initiated after receiving an application from Changfei Fiber Optic Cable Co. alleging suspected circumventing of China’s anti-dumping measures. China currently imposes a 33.3%-78.2% anti-dumping duty on US-originated fiber optic products.
The investigation may affect Corning Incorporated, OFS Fitel LLC, and Draka Communications Americas, Inc., and other related US exporters.
