On Feb 24, 2026, China placed 20 Japanese firms, including Subaru, on an export control watchlist for unverifiable end-use of dual-use items. This signals tighter controls on critical minerals and tech amid geopolitical and supply chain shifts. The analysis examines the firms' supply chain roles and the long-term industrial implications.

On February 24, 2026, China's Ministry of Commerce issued Announcement No. 12 of 2026, adding 20 Japanese entities, including Subaru Corporation, to the export control "watch list" on the grounds of "inability to verify the end-users and end-uses of dual-use items." This move marks the first time since January 2026 that China has explicitly implemented such list-based management measures targeting Japanese enterprises, signaling a shift toward more precise, systematic, and in-depth development of export controls in the fields of critical minerals and high-tech materials. This article will conduct an in-depth analysis of the core backgrounds of these 20 enterprises, reveal their deep-seated connections with supply chains of critical materials such as rare earths, and explore the potential impact of this measure on the future global industrial landscape.

The General Administration of Customs has issued an announcement regarding customs inquiries related to the export control of dual-use items. If the exporter fails to present the license issued by the national export control authority to the customs, and the customs has evidence indicating that the exported goods may fall within the scope of export control, the customs shall raise an inquiry to the exporter and issue a "Notice of Customs Inquiry on Export Control of Dual-Use Items". During the period of identification or inquiry, the customs shall not release the relevant exported goods. The original text is as follows: Announcement No. 123 of 2025 of the General Administration of Customs (Announcement on Matters Related to Customs Inquiries on Export Control of Dual-Use Items) To further optimize the customs inquiry process for export control of dual-use items, in accordance with the provisions of the Customs Law of the People's Republic of China, the Export Control Law of the People's Republic of China, and the Regulations of the People's Republic of China on Export Control of Dual-Use Items, the following matters are hereby announced: 1. If the exporter fails to present the license issued by the national export control authority to the customs, and the customs has evidence indicating that the exported goods may fall within the scope of export control, the customs shall raise an inquiry to the exporter and issue a "Notice of Customs Inquiry on Export Control of Dual-Use Items" (Attachment 1). 2. The exporter shall submit the following materials as required within 7 working days after receiving the "Notice of Customs Inquiry on Export Control of Dual-Use Items". The materials shall be stamped with the official seal, and the exporter shall be responsible for their authenticity: (1) Paper customs declaration form; (2) Export goods contract; (3) Explanation (stating the performance indicators, main uses of the goods, and reasons for believing that they do not fall within the scope of export control); (4) Inspection and detection reports and other relevant technical materials; (5) Other materials required by the customs according to regulatory needs. If the materials are in a foreign language, a Chinese translation shall also be provided. 3. After receiving the materials submitted by the exporter, the customs shall make a determination or propose to organize an identification in accordance with the law, and handle the matter in accordance with the law based on the following circumstances, and issue a "Notice of Results of Customs Inquiry/Organized Identification on Export Control of Dual-Use Items" (Attachment 2). (1) If it is determined that a license for dual-use items is not required, the enterprise shall be notified to proceed with subsequent procedures. (2) If it is determined that a license for dual-use items is required, the exported goods shall not be released and shall be handled in accordance with the regulations. (3) If it is impossible to determine whether the goods are dual-use items, an application for identification shall be submitted to the national export control authority in accordance with the law, and the matter shall be handled in accordance with the identification conclusion. 4. During the period of identification or challenge, the customs will not release the relevant exported goods. This announcement is hereby made. Annexes: 1. Customs Challenge Notification for Export Control of Dual-Use Items.docx 2. Notification of Organizational Identification Results for Customs Challenge in Export Control of Dual-Use Items/Notification of Organizational Identification Results.docx General Administration of Customs June 16, 2025 Download link for the announcement text: Announcement of the General Administration of Customs on Matters Related to Customs Challenges in Export Control of Dual-Use Items.doc Announcement of the General Administration of Customs on Matters Related to Customs Challenges in Export Control of Dual-Use Items.pdf Click to view the original link: 》Announcement No. 123 of the General Administration of Customs in 2025 (Announcement on Matters Related to Customs Challenges in Export Control of Dual-Use Items)

On June 12, at the 2025 SMM (13th) Minor Metal Industry Conference - Main Forum, hosted by Shandong Humon Smelting Co., Ltd. and SMM Information & Technology Co., Ltd., Zhao Wuzhuang, former Deputy Director of the Policy Research Office of the China Nonferrous Metals Industry Association, shared the topic of "Export Controls on Dual-Use Items" with the attendees. He stated that in the past two years, the Chinese government, in accordance with international legal documents such as the conventions on the prohibition of nuclear proliferation and weapons of mass destruction, as well as the management catalog of dual-use items established by these conventions, has introduced measures to strengthen export controls on rare and scattered metals such as indium, germanium, and gallium. As of now, China has implemented export controls on 15 nonferrous metals classified as dual-use items, including four rare and scattered metals (indium, gallium, germanium, and tellurium), four rare metals (tungsten, molybdenum, antimony, and bismuth), and seven rare earth metals (samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium).

A spokesperson for the Ministry of Commerce answered questions from reporters regarding the special campaign to combat the smuggling and export of strategic minerals. Question: We have noticed that the Office of the National Export Control Coordination Mechanism recently deployed a special campaign to combat the smuggling and export of strategic minerals. What considerations were behind this special campaign? What other work will be carried out? Answer: Strengthening export controls on strategic mineral resources is crucial to national security and development interests. Since the implementation of export controls on some strategic minerals, we have discovered that some overseas entities have colluded with domestic lawbreakers in an attempt to evade export control measures through smuggling and other means. To curb the momentum of smuggling and other activities, the Office of the National Export Control Coordination Mechanism held an on-site meeting in Shenzhen, Guangdong Province, on May 9, focusing on combating the smuggling of strategic minerals, and made special arrangements. A series of actions will also be organized in the near future. The on-site meeting further clarified the task divisions among the Ministry of Commerce, the Ministry of Public Security, the Ministry of State Security, the General Administration of Customs, the State Post Bureau, and other departments in this special campaign. It required relevant departments to strengthen law enforcement collaboration, severely crack down on the smuggling and export of strategic minerals, form a high-pressure situation of "joint efforts and shared responsibilities," adopt practical and effective measures, and resolutely prevent the illegal outflow of strategic minerals. Relevant departments immediately took action, swiftly launching cross-departmental investigations and case consultations targeting illegal and irregular activities that attempt to evade export controls, such as false declarations, concealment, smuggling through concealment, and transshipment via a "third country," which have recently emerged in the field of strategic minerals. They intensified port inspections and crackdown efforts, delved deep into uncovering illegal entities and smuggling networks behind the scenes, investigated and handled illegal cases strictly and promptly, continuously enhanced the effectiveness of export control law enforcement, and effectively safeguarded national security and development interests.

SMM, May 12: Metal Market: As of the daytime close, domestic market base metals all rose. SHFE nickel increased by 2%, SHFE aluminum by 1.66%, SHFE lead by 1.22%, SHFE zinc by 1.08%, while SHFE copper and SHFE tin both rose by less than 1%. The main alumina contract rose by 0.67%. In addition, the main lithium carbonate contract rose by 0.53%, the main polysilicon contract by 2.49%, and the main silicon metal contract by 0.24%. The main European container shipping contract surged, ultimately closing at the daily limit of 16%. The ferrous metals series collectively rose, with rebar and HRC increasing by 1.52% and 1.51%, respectively. Iron ore rose by 3.16%, and HRC by 1.51%. In the coking coal and coke sector, coke rose by 0.75%, and coking coal by 0.68%. In the overseas market, as of 15:31, LME base metals all rose. LME lead increased by 0.86%, LME zinc by 1.75%, LME aluminum by 1.68%, LME copper by 1.23%, LME tin by 0.99%, and LME nickel by 0.51%. In the precious metals sector, as of 15:31, COMEX gold fell by 2.81%, and COMEX silver by 0.21%. Domestically, SHFE gold fell by 2.01%, and SHFE silver rose by 1.02%. Market conditions as of 15:31 today 》Click to view SMM Market Dashboard Macro Front Domestic Aspect: [Ministry of Commerce: Crack Down on Smuggling and Export of Strategic Minerals, Increase Inspection and Enforcement Efforts at Ports] A spokesperson for the Ministry of Commerce responded to questions from reporters regarding the special campaign to crack down on the smuggling and export of strategic minerals. Question: We have noticed that the National Export Control Coordination Mechanism Office recently deployed a special campaign to crack down on the smuggling and export of strategic minerals. What considerations are behind this campaign? What other work will be carried out? Answer: Strengthening export controls on strategic mineral resources is crucial for national security and development interests. Since implementing export controls on some strategic minerals, we have discovered that some foreign entities have colluded with domestic lawbreakers to evade export control measures through smuggling and other means. To curb smuggling and other trends, the National Export Control Coordination Mechanism Office held an on-site meeting in Shenzhen, Guangdong Province, on May 9, focusing on cracking down on the smuggling of strategic minerals, and made special arrangements. A series of actions will also be organized in the near future. The on-site meeting further clarified the task divisions among the Ministry of Commerce, the Ministry of Public Security, the Ministry of State Security, the General Administration of Customs, the State Post Bureau, and other departments in this special campaign. It required relevant departments to strengthen law enforcement collaboration, severely crack down on the smuggling and export of strategic minerals, form a high-pressure situation of "joint management and control," take practical and effective measures, and resolutely prevent the illegal outflow of strategic minerals.Relevant departments immediately took action to swiftly launch cross-departmental investigations and case consultations targeting recent illegal and irregular activities in the strategic minerals sector aimed at evading export controls, such as false declarations, concealment, smuggling through concealment, and transshipment via "third countries." They intensified inspection and enforcement efforts at ports, delved deep into uncovering illegal entities and smuggling networks operating behind the scenes, and rigorously and swiftly investigated and handled illegal cases. This ongoing effort aims to continuously enhance the effectiveness of export control law enforcement and effectively safeguard national security and development interests. (Cailian Press) [The Meeting on Strengthening the Whole-Chain Management and Control of Strategic Minerals Exports was Held] To thoroughly implement the decisions and arrangements of the CPC Central Committee and the State Council, on May 12, 2025, the Office of the National Export Control Coordination Mechanism organized the Ministry of Commerce, the Ministry of Industry and Information Technology, the Ministry of Public Security, the Ministry of State Security, the Ministry of Natural Resources, the Ministry of Transport, the State-owned Assets Supervision and Administration Commission of the State Council, the General Administration of Customs, the State Administration for Market Regulation, the State Post Bureau, and local authorities from strategic minerals-rich provinces such as Inner Mongolia, Jiangxi, Hunan, Guangdong, Guangxi, Guizhou, and Yunnan to convene the Meeting on Strengthening the Whole-Chain Management and Control of Strategic Minerals Exports in Changsha City, Hunan Province. ► The central parity rate of the RMB exchange rate in the inter-bank foreign exchange market on May 12 was 1 US dollar to 7.2066 yuan. US dollar: As of 15:31, the US dollar index rose by 1.08% to 101.49. The release of the joint statement on the China-US Geneva Economic and Trade Talks has alleviated market concerns about tariffs. The spokesperson for the Ministry of Commerce made remarks on the joint statement. This round of high-level economic and trade talks between China and the US has achieved substantive progress, significantly reducing bilateral tariff levels. The US has removed a total of 91% of the tariff hikes, and China has correspondingly removed 91% of the retaliatory tariffs. The US has suspended the implementation of 24% of the "reciprocal tariffs," and China has also correspondingly suspended the implementation of 24% of the retaliatory tariffs. Beth Hammack, President of the Federal Reserve Bank of Cleveland, stated on Friday that the US Fed needs more time to observe the economy's response to US tariffs and other policies before finding the right countermeasures, noting that much of the government's agenda remains unclear. Traders are closely watching the US Consumer Price Index (CPI) to be released on Tuesday for new signals regarding the monetary policy outlook of the Federal Reserve (Fed). Macro: [Joint Statement on the China-US Geneva Economic and Trade Talks] ① Both sides committed to taking a series of measures before May 14, 2025, including revising and removing tariffs imposed on each other's goods, as well as suspending or removing non-tariff retaliatory measures.② Both sides will establish a mechanism to continue consultations on economic and trade relations, and may hold discussions in China, the US, or a third country. (Xinhua News Agency) 》Click for details Also worth monitoring: Data to be released today include China's M2 money supply YoY for April, China's total social financing (TSF) year-to-date for April, China's new RMB loans year-to-date for April, changes in Canada's employment for April, Canada's unemployment rate for April, etc. Also note the speech by Federal Reserve Governor Adriana Kugler; the National Energy Administration's release of nationwide electricity consumption data around the 15th of each month is also worth monitoring. Crude oil: As of 15:31, crude oil futures rose across the board, with WTI up 2.82% and Brent up 2.61%. Oil prices rose as easing global trade tensions boosted market sentiment. Toshitaka Tazawa, an analyst at Fujitsu Securities, said that easing trade tensions supported market confidence, but OPEC's plans to increase production limited gains. Tazawa was referring to the plan by the Organization of the Petroleum Exporting Countries and its allies (collectively known as OPEC+) to accelerate production increases in May and June, which will add more crude oil to the market. However, surveys showed that OPEC's oil production fell in April. (Wenhua Comprehensive) SMM Daily Review ► Copper inventories in major regions across China increased slightly by 3,000 mt over the weekend [SMM Weekly Data] ► Poor price ratios in the morning session led to sluggish offers and thin trading activity [SMM Yangshan Spot Copper] ► Increased production cuts in secondary lead led to a slight decline in social inventory of zinc ingots [SMM Social Inventory of Zinc Ingots] ► SMM's social inventory of zinc ingots in seven regions increased by 2,200 mt [SMM Data] ► [SMM Daily Review of Nickel Sulphate] On May 12, nickel sulphate prices held steady ► [SMM Iron Ore Shipping Data] Global shipments continued to decline slightly, while port arrivals increased slightly ► [SMM Steel Shipping] China's total steel exports fell 18% MoM last week ► [SMM Coking Coal Shipping] Total coal arrivals at SMM ports reached 7.101 million mt ► Progress made in China-US economic and trade talks; precious metal prices corrected in the morning session, with overall spot trading remaining sluggish [SMM Daily Review]