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A far-reaching agreement in the US–China trade dispute temporarily eases export controls and tariffs. While companies may benefit from this development, they should nevertheless review political risks and potential vulnerabilities in their supply chains.
In the trade dispute between the United States and China, the two major powers have reached a comprehensive agreement. The Chinese Ministry of Commerce (MOFCOM) has announced that it will suspend the tightened export controls on the delivery of dual-use goods to the United States for approximately one year. The measures particularly affect products containing gallium, germanium, antimony, and superhard materials, which are primarily used in semiconductor technology.
In addition, on November 7, 2025, MOFCOM suspended the stricter export control regulations introduced through Announcements 55, 56, 57, 58, 61, and 62 for the same period by issuing Announcement No. 70. These regulations had significantly tightened controls on superhard materials and rare earths. For example, Announcement No. 61 expanded the regulation of the re-export of rare earths and introduced a de minimis threshold of 0.1 % for the control of products manufactured abroad that contain Chinese rare earths as originating components. Further details on this topic are available here.
The US also announced measures to remove trade barriers: tariffs on Chinese imports will be reduced, tariff exemptions extended, and trade restrictions on Chinese products and companies temporarily suspended. In return, China signaled a willingness to compromise on its tariff policy and suspended retaliatory tariffs against the US
There is also positive news from a European perspective in the dispute surrounding the chip manufacturer Nexperia: following prior authorization, computer chips may now once again be partially supplied to Europe for civilian purposes.
For European companies, this easing of trade regulations represents a significant relief in trade with business partners in China and the United States. At the same time, however, the export control rules recently tightened by China illustrate that Beijing may significantly expand the extraterritorial application of its regulations. The United States has likewise signaled the possibility of substantially tightening trade-related restrictions. In addition, many of the rollbacks are only temporary.
Companies should therefore carefully assess the vulnerability of their supply chains in light of political risks and, where appropriate, consider diversification. Continuous monitoring of global legal developments remains essential in order to respond to changes at an early stage.
Please do not hesitate to contact us if you have any questions on this matter.
Mareike Höcker
Manager
Attorney-at-Law (Rechtsanwältin)
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