June 4, 2026No Comments

The Strategic Logic of China’s April 2026 Supply Chain Regulations

By Sandra Watson Parcels - China & Asia Team

The April 2026 Chinese State Council regulations on industrial and supply chain security introduce a compliance trap with no clean exit. Foreign companies operating in both Western and Chinese markets now face a structural dilemma: complying with Western export controls or sanctions may qualify as grounds for designation and penalty under Chinese law, while failing to comply risks Western penalties. This is not an incidental feature of the regulations. It is their strategic function. The regulations comprise two instruments, the Provisions on the Security of Industrial and Supply Chains and the Provisions on Countering Improper Extraterritorial Jurisdiction by Foreign States, and expand the capacity to investigate, restrict, and penalise foreign companies and governments accordingly. They are the latest iteration of a framework treating economic interdependence as an instrument of state power, one that has grown more institutionalised and operationally precise over time.

The Expanding Toolkit

China has built a set of interwoven economic pressure tools over the past several years. The April 2025 licensing controls on seven medium and heavy rare earth elements (samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium) established Beijing's capacity to restrict access to materials where it controls over 80 percent of global processing capacity. While some extraterritorial features of later 2025 measures were suspended until November 2026, the core licensing framework remains active. The April 2026 supply chain security regulations extend this framework. The Provisions on Security of Industrial and Supply Chains permit Chinese authorities to designate foreign entities as threats to industrial security and impose escalating responses including trade restrictions, investment blocks, and visa limitations. The criteria for designation are extensive and include acts as routine as complying with foreign export controls or sanctions.

The counter-extraterritorial provisions operationalise this trap. The Provisions on Countering Improper Extraterritorial Jurisdiction give Chinese authorities broad discretion to penalise companies that comply with foreign controls, without requiring proof of intent. Complying with European Union (EU) or United States (US) rules is sufficient grounds for designation. The practical consequences are hesitation, delayed investment decisions, and in some cases withdrawal from market positions that would otherwise support allied supply chain goals. The legal framework does not require companies to choose China. It requires them to avoid choosing against it. 

Strategic Patterns and Objectives

This approach follows patterns established in earlier measures where Beijing arranged economic instruments in response to actions it opposed, whether on Taiwan, technology security, or alliance coordination. The consistent objective has been to encourage restraint among governments and self-censorship among firms without crossing into armed conflict. The G7 trade ministers addressed this in their May 2026 statement from Paris, expressing concern about economic coercion through export restrictions that risk supply chain disruptions, particularly for critical minerals, and undermine economic security and resilience. That G7 trade ministers felt compelled to address this directly in a formal communiqué reflects how far the issue has moved from technical trade policy into the domain of security strategy. Western policy frameworks have yet to fully institutionalise that shift. The strategic logic is to slow or complicate moves toward supply-chain independence in sectors including defence, electric vehicles, renewables, and advanced manufacturing. By concentrating leverage at processing chokepoints rather than raw material extraction alone, the approach creates costs that are asymmetric and difficult for individual states to absorb unilaterally.

Implications for Europe and Allied Partners

European states, including Italy, face direct exposure. Many industries remain dependent on Chinese processing capacity for critical minerals used in batteries, defence systems, and green technology. European defence procurement in particular relies on rare earth elements for guidance systems, radar, and propulsion technologies where alternative processing capacity outside China remains limited. The April 2026 regulations mean companies with exposure in both markets now face that compliance trap directly. The compliance trap does not affect companies in isolation. When one state faces economic pressure, others frequently hesitate to act in solidarity, which deepens instead of eases vulnerability. This fragmentation is what the regulatory framework exploits. But fragmentation is not inevitable. It reflects political incentives that individual states have so far been unwilling to override. Understanding why collective hesitation persists matters as much as documenting it.

North America illustrates both the exposure and the gap. American companies operating in China that comply with US forced labour due diligence or technology transfer requirements now risk designation under the new regulations. What a compliance officer treats as routine legal obligation, Chinese authorities may treat as a qualifying act. Canada's experiencefollowing the Meng Wanzhou arrest demonstrated how targeted pressure can leave a middle power with limited unilateral options, and the broader pattern holds: collective resistance breaks down as individual states calculate that bilateral accommodation is less costly than holding a common line. For middle powers, the compliance trap is easier to navigate collectively than alone. Canada's positioning on critical minerals compounds this. The advantage cited in recent policy discussions rests on extraction capacity, not processing capacity. Canada extracts. Others process. That is the specific gap the current regulatory leverage exploits.

Photo by CHUTTERSNAP on Unsplash

Policy Considerations

Addressing this challenge requires treating economic coercion as structural, not periodic trade friction. Generic diversification language understates what that requires. Public investment should target processing capacity in allied jurisdictions directly, since extraction diversification alone does not address the chokepoint through which current leverage operates. For the G7 and EU, this means jointly funding processing infrastructure rather than leaving it to market incentives that have so far failed to close the gap. Within NATO, early warning and coordinated response mechanisms for economic coercion deserve the same institutional attention currently given to cyber threats. For companies, resilience planning should map exposure at the processing stage specifically, not just at the extraction or finished goods level, since that is where the compliance trap bites hardest. Due diligence frameworks and open market arrangements among allied and partner states would reduce the dilemmas companies currently face, but only if governments provide clarity on which compliance obligations take precedence and under what conditions. The compliance trap is a legal design. Dismantling it requires a legal and institutional response, not only a supply chain one.

Concluding Assessment

The April 2026 regulations add legal precision and institutional reach to a framework that has been developing for several years. The compliance trap they formalise is not a byproduct of competing regulatory systems. It is a structural feature designed to raise the cost of coordinated responses while remaining below the threshold of direct confrontation. The chokepoint is processing, not extraction, and current Western policy responses have not consistently targeted it. Treating these instruments with the same analytical seriousness as military or cyber threats is warranted, not because the risks are equivalent, but because the effects on industrial capacity, alliance cohesion, and strategic autonomy are consequential and harder to reverse. The vulnerabilities are understood. The processing gap is specific enough to act on. The question is whether policy follows analysis.

December 26, 2025No Comments

China-US Pause in Busan: Divorce in the Age of Supply Chains

By Carlotta Rinaudo - China & Asia Team

The trade war between the United States and China increasingly resembles a failed divorce: expensive, chaotic, and ultimately impossible to finalize. Both sides threaten separation only to discover they are too deeply entangled to walk away: in October 2025 in Busan, the two unwilling partners found themselves forced back under the same marital roof. To make sense of this strange and dysfunctional relationship, over time many analysts have turned to an unexpected field: couple psychology

Some analysts describe the relationship as a pragmatic partnership that dates back to the 1970s, forged out of necessity rather than mutual trust or alignment. The United States was burdened by the huge costs of the Vietnam War and a period of stagflation. Prices were rising, workers’ salaries were not, and consumption, the very engine of the American economy - was under threat. China, on the other side of the Pacific, was poor, isolated, and hungry for growth. The stage was set for what Zeno Leoni calls a “marriage of convenience”: two countries using one another as a quick fix for weaknesses they could not resolve alone. As Han Feizi puts it, it was an unlikely relation built on a clear imbalance: on one side, a weak country would work its way out of poverty, save aggressively, and lend money to a rich partner with a reckless spending habit – who would then use that money to buy even more of the poor country’s products. Strange as it sounded, the arrangement worked.

Walmart aisles quickly filled with low-cost clothes, toys, electronics, and household goods, contributing to affordable consumerism during a period of stagnant wages for many. Products that once felt like luxuries became accessible to most American families. For China, the benefits were just as tangible. American demand kept factories running, while millions of rural workers migrated to the coast in search of jobs that offered them a way out of poverty. Dollars flowed from US consumers to Chinese factories and then flowed back to Washington as purchases of US debt, allowing Americans to borrow and consume even more. As Stephen Roach said, China gave Americans a way to “repeal the basic laws of economics”: they could “live beyond their means, and that enabled the Chinese to do the same.” 

Like many toxic relationships, however, this marriage of convenience also amplified each partner’s worst imbalances. In the United States, easy access to cheap imports deepened debt and hollowed out industrial towns like Martinsville, Virginia, where textile factories closed, jobs disappeared, and communities were left behind as production shifted overseas. In China, the costs were even more visible: rivers were polluted, air quality was deteriorated, and laborers were overworked. Also, like in human relationships, over time China’s behavior changed in ways that left the other feeling insecure. No longer a poor country desperate for jobs and dollars, China gradually became an industrial and technological powerhouse. With that rise came confidence, nationalism, and a growing desire to assert itself on the global stage. Also, China was no longer confined to filling Walmart aisles with cheap goods: now it began competing in advanced sectors once dominated by the US – from AI and telecommunications to robotics. For Washington, this shift in balance triggered something like an identity crisis, which brings us to the mutual resentment, finger-pointing, anxiety and suspicion we are seeing today. In human terms, this is often the stage that leads to separation, and the United States first attempted to follow that script. Washington began to openly speak of decoupling - a necessary “surgical strike” to reduce dependence on China, de-risk critical supply chains, and bring manufacturing jobs back home. US Commerce Secretary Howard Lutnick went so far as to imagine an “army” of workers assembling iPhones in the United States. The attempted separation reached its peak on what was called “Liberation Day”, when President Donald Trump imposed tariffs of up to 145% on Chinese products – to which China promptly responded. 

Yet this tit-for-that soon revealed how separation between two economic giants can be messy, expensive, and ultimately self-defeating. Tariffs were not deployed like precision weapons, but more like land mines, harming almost everyone in their way. American workers and consumers – those the measures were meant to protect – quickly found themselves caught in the middle. Chinese-manufactured toys that once sold for $21.99 now cost $35, forcing long-standing toy storesin Manhattan to close. Farmers across the Midwest saw sales collapse as China restricted purchases of US soybeans. Nvidia, the crown jewel of American AI, lost billions of dollars in revenue due to restrictions on chip sales - money that could have been reinvested in domestic research. Even more, those same restrictions accelerated China’s push toward technological self-sufficiency. 

The deeper lesson, however, goes beyond tariffs. In today’s interconnected supply chains, economic measures often have ripple effects, meaning that actions taken against a partner can have unintended consequences for both sides. Donald Trump often speaks of goods as if they were either “Made in China” or “Made in America,” yet while that worldview made sense in the industrial economy of the twentieth century, it does not make sense in the reality we live in today. In the age of container shipping and digital coordination, almost nothing is fully “made” in one place only: products are, more often than not, assembled from components sourced across multiple countries. Huawei - often depicted as the embodiment of “Made in China” – actually relies heavily on US firms such as Qualcomm and Broadcom for some of its components, and for years its operating system was Google’s Android. This means that sanctions aimed at Huawei inevitably end up harming US companies too. Such is the power of the supply chain in the 21st century. 

Photo by mohamed_hassan (pixabay.com)

Rare earths offer an even starker example of how US attempts to project strength can expose new vulnerabilities at home. China controls much of the global supply chain of these critical materials, essential for everything from electric vehicles to advanced weapon systems. When Beijing restricted exports in retaliation for US tariffs, the consequences were immediate. To mention one, Ford shut down a factory in Chicago after it was unable to secure the rare earths needed for electric motors. Research showed that it would take eight to twelve years to rebuilding domestic refining capacity of these materials – if Americans would be willing to shoulder the dirty business of rare earth refining itself. Looking at Baotoutoday, a dry town in China’s Inner Mongolia, it is clear that reshoring production would mean accepting environmental costs that Americans have long outsourced to China. In Baotou, decades of processing have poisoned groundwater and produced a “cancer epidemic” throughout what they are now known as “cancer villages.” 

In October 2025, President Trump and President Xi Jinping met in Busan. The meeting felt less like a resolution and more like a tacit recognition of limits. Leading a slowing economy, Xi urged Trump to learn from the recent “twists and turns” of the trade war. On his side, Trump agreed to cut tariffs to 47% and called a “ceasefire” on further escalation. Beijing, in turn, suspended restrictions on rare earth exports for one year. It was, overall, a pause that restored a fragile status quo while leaving the underlying tensions intact. Yet the Busan meeting made one reality impossible to ignore. Over decades, the US and China built production systems projected to function together – one side designing, consuming, and spending; the other manufacturing, assembling, and absorbing the environmental cost. That same structure is now dictating the terms of the relationship for both partners. In a supply-chain world, even an unhappy and suffocating marriage can be cheaper to endure than to escape. And for two unwilling partners forced together by necessity rather than affection, learning how to live together may eventually prove easier than walking away.