In October 2025, China’s Ministry of Commerce and the General Administration of Customs jointly announced new export controls on rare earths, introducing restrictions on a range of medium and heavy rare earth elements such as holmium and erbium. The new rules will take effect on November 8, 2025.
The move sparked an immediate and furious reaction from the United States. Donald Trump publicly lashed out, claiming the controls “cover a massive range of non–China-made products” and calling them “unheard of.” He went on to say, “This affects every country, without exception—it’s clearly a plan they made years ago.”
But a closer look reveals that each of China’s countermeasures can be traced directly to U.S. policy precedents. In truth, what Trump calls “retaliation” is nothing more than a mirror image of America’s own trade control logic.
Content Threshold Control: Borrowed Directly from America’s “Technology Tracing” Rules
China’s new regulation requires approval for any product containing more than 0.1% of Chinese rare earth components. This approach is clearly inspired by the United States’ technology-tracing rules.
Back in 2020, Washington imposed strict export controls on Huawei, stipulating that any product containing U.S. technology—regardless of where it was made—must obtain U.S. approval before being sold to Huawei.
This “component ratio” rule, which requires approval even if the U.S. content exceeds 0%, broke from traditional trade practice that relied on “final manufacturing location” as the standard—including America’s own previous rule of ignoring components under 10%.
Now China is applying that same principle to rare earths. By using rare earths as a strategic anchor and tracing their content, Beijing is enabling precise regulation. Just as the U.S. once used technology to bind the global supply chain, China is now using rare earths to reshape the export order—a direct echo of the American model of trade control.
Full-Chain Control on Rare Earth Exports: Copying the U.S. Semiconductor Framework
The current measures cover not only rare earths themselves, but also downstream products manufactured with Chinese rare earths, technology, or equipment. Exports of such products also require government approval.
This full-chain control framework closely mirrors the U.S. semiconductor restrictions imposed on Huawei.
To contain Huawei’s rise, the U.S. not only limited domestic semiconductor equipment exports but also built a full-chain system of “equipment–production–foundry.” Any chip made using American equipment, if supplied to sanctioned firms like Huawei, required U.S. authorization.
Now, China has adopted the same “from upstream to downstream” approach in the rare earth sector. From raw ore to processed materials and final products, every stage requires approval—essentially recreating the U.S. supply-chain blockade model.
In theory, this means that chips made by TSMC using American tools would now require Chinese approval if they contain controlled rare earth materials.
Penetrating Oversight of Shipping Companies: Modeled on the U.S. “Entity List” Expansion Rule
China’s Ministry of Transport recently introduced special port fees for shipping companies with more than 25% U.S. ownership—a move grounded in the same “penetrating regulation” logic used by the United States.
On September 29, 2025, the U.S. Department of Commerce issued an interim final rule extending “Entity List” controls to subsidiaries where listed entities hold 50% or more ownership, effectively expanding control through shareholding relationships.
China’s approach mirrors this logic. By setting a 25% threshold, it precisely targets market entities heavily influenced by U.S. capital. Just as the U.S. defines its control targets through equity ratios, China is now doing the same—using “penetrating shareholding” to assess real influence.
The U.S. uses penetrating rules to widen sanctions; China uses similar reasoning to apply differentiated regulation. Both are based on the same tool—only now the direction has reversed.
Antitrust Enforcement: Responding to America’s Selective Punishment Model—But with More Fairness
China’s antitrust investigation into Qualcomm’s unreported acquisitions may appear to be a standalone action, but it’s actually a direct response to Washington’s selective law enforcement.
The U.S. previously punished Huawei for acquiring the bankrupt and unwanted “Three Leaf” company, citing procedural violations. That move politicized normal business mergers and selectively applied legal standards—well beyond the boundaries of normal enforcement.
China’s antitrust probe into Qualcomm, by contrast, is strictly conducted under domestic antitrust laws. Yet it subtly mirrors the American approach—using legal tools to address behavior seen as unfair or monopolistic.
If the U.S. can weaponize law to suppress competitors, China can just as legitimately use compliant enforcement to maintain market order. This “regulating against abuse” strategy lays bare the U.S.’s double standards: when their own companies face similar scrutiny, the rhetoric of “legal legitimacy” quickly collapses.
From rare earth export controls to the 25% ownership rule on shipping firms, every one of China’s countermeasures can find its origin in U.S. policy.
Trump’s anger reflects not moral outrage, but disbelief at being struck by his own logic—a textbook case of “the hunter becoming the hunted.”
The very trade control toolbox that America built has now become a legitimate weapon for China to defend its national interests.
After years of demonstrating these tools to the world, the U.S. now faces its own creation turned against it—a hegemonic weapon transformed into a boomerang.
And perhaps the most ironic part? When Trump attacks China over these policies, the comments below are filled with Americans saying, “You reap what you sow.”