In recent years, China has positioned itself in international forums as a critic of what it describes as the “abuse” of export controls by major powers, particularly the United States and its allies. Speaking at the United Nations General Assembly and other multilateral platforms, Beijing has argued that such measures unfairly restrict developing countries’ access to science and technology, undermining the principles of equitable global cooperation. However, a detailed analysis by the Stockholm International Peace Research Institute (SIPRI) highlights a growing contradiction between this rhetoric and China’s own expanding use of export controls as a tool of statecraft.
According to the SIPRI commentary, China has significantly strengthened its domestic export control framework since 2020, building a system that not only aligns more closely with international regimes but also provides Beijing with powerful mechanisms to exert economic pressure and pursue geopolitical objectives. While export controls are traditionally designed to prevent the proliferation of weapons of mass destruction and sensitive dual-use technologies, China’s evolving system increasingly reflects a broader strategic logic that includes retaliation, coercion, and supply chain leverage.
The SIPRI analysis explains that export controls are governed globally by four main multilateral regimes: the Australia Group, the Missile Technology Control Regime, the Nuclear Suppliers Group, and the Wassenaar Arrangement. These frameworks set non-binding but widely accepted standards for regulating sensitive goods and technologies. Yet implementation remains national, giving states considerable flexibility to expand controls beyond agreed lists. In practice, major powers have long used these mechanisms not only for non-proliferation but also to advance national security and economic competitiveness.
The United States, for example, has openly integrated export controls into its strategy to maintain technological leadership, often applying unilateral restrictions. The European Union has also moved toward a more security-driven approach, linking export controls to broader economic resilience concerns. SIPRI notes that China’s recent trajectory mirrors these developments, albeit with distinct characteristics shaped by its geopolitical rivalry with Washington and its ambitions to reshape global governance norms.
A key turning point came with the adoption of China’s 2020 Export Control Law, which established a unified legal framework governing dual-use items, military goods, nuclear materials, and other sensitive technologies. Subsequent regulations, including updated dual-use control rules in 2024, have refined licensing systems and consolidated previously fragmented oversight mechanisms. These reforms have brought China closer to international standards in terms of regulatory structure and technical specificity.
However, SIPRI emphasizes that the same legal architecture also enables Beijing to extend control beyond traditional non-proliferation concerns. One of the most significant innovations is the extraterritorial application of Chinese export control law. This means that foreign companies re-exporting Chinese-origin goods, or products containing Chinese components, may fall under Beijing’s regulatory authority. Only the United States has historically applied similar extraterritorial reach, a practice that has often generated diplomatic friction.
Since 2023, China has increasingly deployed export controls on critical raw materials such as rare earth elements, gallium, germanium, and antimony. While some of these materials are included in multilateral control lists under specific technical thresholds, China’s measures often exceed those standards and apply broader restrictions, including to materials not traditionally classified as dual-use. SIPRI notes that this expansion reflects not only non-proliferation concerns but also strategic economic considerations, particularly given China’s dominant position in global supply chains for critical minerals.
In parallel, China has developed end-user-based control mechanisms that closely resemble tools used by the United States. These include entity lists, “watch lists,” and the Unreliable Entity List, which restrict or prohibit trade with foreign firms deemed to threaten China’s national security or violate export regulations. According to SIPRI, these instruments collectively form a flexible system that can be activated selectively against foreign companies or governments.
The report highlights how these tools have increasingly been used in response to geopolitical tensions. Following escalating trade disputes with the United States during both the Biden and Trump administrations, China imposed export restrictions on several critical materials and tightened licensing requirements for exports to U.S. military end-users. Similar measures were later directed at Japanese entities amid political disputes over Taiwan, and at European firms in response to EU sanctions targeting entities accused of supplying dual-use goods to Russia.
These actions, SIPRI argues, demonstrate that China’s export control system is not merely regulatory but also retaliatory. By leveraging its dominant position in critical mineral production and processing, Beijing has been able to introduce measures that disrupt global supply chains while signaling political displeasure. Although many of these restrictions are framed as licensing requirements rather than outright bans, in practice they can function as de facto embargoes due to complex approval processes and limited transparency.
European importers have reported significant delays and uncertainty in obtaining export licenses, including extensive documentation requirements such as end-use disclosures, production details, and supply chain information. In some cases, SIPRI notes, the administrative burden has effectively blocked access to critical materials, underscoring the practical impact of China’s regulatory tightening.
At the multilateral level, China has simultaneously maintained a critical stance toward export control regimes. Through a series of resolutions at the United Nations General Assembly in 2021, 2022, and 2024, Beijing has argued that such measures impose “undue restrictions” on developing countries and violate their right to access peaceful technologies. These initiatives have occasionally suggested the possibility of alternative governance frameworks outside existing regimes.
SIPRI notes that this rhetoric aligns with longstanding positions held by many developing states, particularly within the Non-Aligned Movement, which has historically criticized technology restrictions imposed by industrialized powers. However, China’s continued membership in the Nuclear Suppliers Group and its participation in multilateral discussions on control lists suggest a more nuanced position, combining institutional engagement with systemic critique.
Domestically, Chinese authorities frame export controls as legitimate tools of national security rather than instruments of coercion. Restrictions on critical materials are justified as necessary to prevent their diversion into foreign military applications, while controls on Japan have been linked to concerns over remilitarization and regional security dynamics. Officials argue that these measures are consistent with international non-proliferation obligations and reflect sovereign rights to regulate sensitive technologies.
SIPRI’s analysis, however, emphasizes that this framing exists alongside a broader strategic narrative. Export controls are increasingly embedded within China’s vision of global governance reform, as reflected in initiatives such as the Global Governance Initiative introduced in 2025. This framework calls for a more “just and equitable” international system but leaves open questions about how such principles would be operationalized in practice.
The report concludes that China’s export control system illustrates a broader global trend in which trade restrictions are becoming instruments of geopolitical competition rather than purely technical non-proliferation tools. While Beijing is not unique in this regard, the scale of its supply chain influence amplifies the global impact of its policies. As a result, export controls are increasingly shaping international relations in ways that extend far beyond their original security mandate.
At the heart of the SIPRI assessment is a central tension: China’s simultaneous critique of export control “abuse” and its own expanding use of similar mechanisms. This duality, the report suggests, reflects both the evolving nature of global power competition and the challenges of maintaining a coherent international framework for managing sensitive technologies in an era of intensifying strategic rivalry.
