The U.S. sanctions list came into effect overnight, and in less than 24 hours Beijing fought back head-on. The second half of the game of technology began?

On October 8, the U.S. Department of Commerce issued an export control update, adding 29 companies from China, Turkey and United Arab Emirates to the "Entity List" and citing vague wording "contrary to U.S. national interests and foreign policy." The real target of this list was quickly revealed-more than half of them are China companies, covering many key industries such as rare earths, advanced manufacturing, and semiconductor equipment.

The announcement has no buffer period and takes effect immediately from the day of publication. There is no exemption application. Most companies have not been warned or named before, which is a "kill first and report later" treatment. At the same time, the U.S. government has not provided specific evidence or a case review mechanism. Instead, it uses a "overall classification" approach and handles it across the board.

Bloomberg analysis pointed out that the essence of this list is not supervision, but a systematic containment of China's technology supply chain. "It's not punishing violations, it's reconfiguring the direction of technology flow."

In the context of Washington’s “penetrating censorship” of China’s industrial chains, the list is more like a sign of a new phase: the United States is using executive power to make technology for the Cold War.

Full chain control.

Less than 24 hours later, the Ministry of Commerce of China announced the revision of the rare-earth export policy, the core change is to include the entire chain export of rare-earth objects and related technologies under the licensing system, and for the first time clearly put forward that even overseas processing, as long as it contains Chinese rare-earth ingredients, also falls under control.

This new regulation contains four key contents:

All export of rare earth items must obtain permission from the Ministry of Commerce;
If the export target is foreign military-industrial users, sensitive list entities, or there is a risk of contributing to the manufacture of weapons of mass destruction, the application will be "principally rejected";
Clearly include "overseas items containing China's rare earth components" into the scope of management, aiming to plug past bypass export loopholes;
Export restrictions are imposed on rare-earth-related technologies (from metallurgy separation, metal purification to magnetic materials manufacturing), and any organization or individual is prohibited from acting as an indirect participant, such as intermediary, transportation, customs reporting.

In other words, China's control of rare earths has moved from raw materials to the stage of "component tracking". This mechanism is essentially a "strategic traceability system."

The core of the rare earth game

Why is the United States so sensitive to rare earth?The answer can be seen from its military-industrial core product list.Whether it is the F-35, the radar components used in the Burke-class destroyer, the microwave guidance system, or the permanent magnetic drive module in the Patriot missile, the rare earth elements are irreplaceable.

In the field of new energy and high-end manufacturing, rare earth is more basic material. Tesla motors, electric vehicle rotors, wind gear systems, high-end crystal polishing processes all rely on rare elements such as rare earth uranium, uranium, uranium.

According to data released by the U.S. Office of Defense Industry Basic Assessment in 2024, more than 80% of the US military's core weapon systems contain rare earth permanent magnets, and more than 90% of them come from China's industrial chain. Although the United States is trying to promote its local rare earth production plan, China still maintains an overwhelming advantage in cost and technology, from ore mining to magnetic processing.

Bloomberg commented that China's "full-chain lock-up" rare earth export mechanism "will force the West to reassess its systematic dependence on China's supply chain", while the US's previous slogan of "establishing a friendly shore rare earth chain" may be difficult to fulfill due to the empty actual production capacity.

Not just resource warfare

The legal basis for the rare-earth control measures is clearly derived from the Export Control Law and the Anti-Foreign Sanctions Law, and is combined with the implementation rules of the "Commodity Catalog Notice" and the "Technical Catalog Notice".

What is more noteworthy is that China has not chosen a "one size fits all" ban in the field of rare earths, but has adopted a "licensing system + classified management" approach: this policy is highly adjustable and can not only block specific sensitive exports, but also It can retain flexible space for friendly and cooperative countries.

This just highlights China's strategic choice: to deal with the game with rules rather than embargoes.

This is no longer the same as the "rare earth export restriction case" in the 2010s. At that time, China was found to be in violation of the rules by the WTO for failing to establish a legal export licensing framework; this time, China implemented "reciprocal responses" in accordance with the law based on "potential military use" and "non-proliferation obligations." Not only is the strategy more mature, but also the legal foundation more solid.

In other words, China has made the transition from “resource exporters” to “export regulators” with rare earth as its starting point, and is building a controllable mechanism for the global flow of high-end goods.

Total escalation of U.S. control?

The blacklist and rare-earth control events marked the expansion of the focus of the Sino-U.S. technology game from "chip-breaking confession" to "material blockade", from software algorithm struggle to resource sovereignty dispute.

After the United States imposed multiple rounds of precise sanctions on chips, semiconductors, and AI algorithms, China countered in tracking export items and ingredients. This is a two-way "institutional decoupling."

It is worth noting that on the eve of the 2026 U.S. election, the topic of technology and national security is becoming a highland for candidates to compete for their positions; and every response from China is not only a short-term economic confrontation, but also a long-term deployment of "key national materials controllable mechanism".

The Qinghai University Institute of Strategic Research recently released a study report that the main axis of global high-end manufacturing competition in the next 10 years is likely to shift from "who can make" to "who can export + who can control the price".

There is no need for a slogan at the end. The US sanctions have opened a road of no return. China's counter-measures are both technical policies and strategic signals. The resource game has just begun, and the next competition may be hidden in another humble periodic table of elements.