Setting the Context

Since the normalisation of United States (US)-China relations in the 1970s, there has been engagement in the economic, cultural, and educational spheres^[1]— cooperation that continued until Donald Trump’s election in 2016. According to the Trump administration’s 2017 National Security Strategy, this collaboration was premised on the belief that Beijing’s assimilation into the international order would encourage political liberalisation.^[2] The 2017 document pointed to America’s innovation system as a factor for China’s economic rise and military modernisation.^[3] Consequently, the Trump administration restricted Chinese telecom company, Huawei’s access to semiconductor technology.^[4] It also targeted Baidu, Alibaba and Tencent through the ‘Clean Cloud’ initiative—a strategy that sought to build public opposition to their cloud storage services expanding into the American market.^[5] The US government also moved to counter China’s influence in the domains of telecommunications infrastructure (including in submarine internet cables), mobile-phone app ecosystems, and cloud computing.^[6]

The succeeding Joe Biden administration expanded these curbs, arguing that the US could not maintain its “sliding scale” approach of staying merely a few generations ahead of competitors. The National Security Advisor at that time, Jake Sullivan, emphasised the need for the US to “maintain as large of a lead as possible” with respect to the development of technology.^[7] Thus, technological contestation became a key battleground between the US and China, even as it was an issue that brought both together the Democrats and Republicans in the US.

US Actions and Technology-Denial Regime

The US has expanded export-control measures against China since 2022. In October 2022, the Biden administration, through the Commerce Department, made it difficult for China to access semiconductors or equipment that helps in its manufacture, and prohibited American nationals from working for a Chinese entity involved in its manufacture or providing technical know-how for those that do.^[8] In December 2024, the Biden administration brought in technology controls in semiconductors that built on earlier restrictions imposed in 2022, and also added new Chinese entities to a trade blacklist. The new regulations now cover not only Chinese semiconductor manufacturers but the entire supporting ecosystem of chip-making equipment and design software that are important components of the sector.^[9] Additionally, there has been a crackdown on the export of memory chips used in Artificial Intelligence (AI) applications.

The rules cover items produced overseas using US technology. Private equity firms investing in China’s technology sector have also been included in the blacklist. These firms were facilitating Beijing’s efforts to secure entities with sensitive semiconductor manufacturing capabilities vital to the defence-industrial bases of the US and its allies. The move reflected the Biden administration’s bid to strike at ancillary links in China’s technology supply chain and built on previous regimes aimed at limiting China’s access to advanced technologies with military implications. In an interim final rule, titled ‘Framework for Artificial Intelligence Diffusion,’ the Biden administration proposed creating three tiers of countries, each subject to specific export restrictions on AI chips and Graphics Processing Units (GPUs).^[a],[10]

Further, under the National Defense Authorization Act of 2021, the government is mandated to regularly update a list of entities that may be aiding and furthering the Communist Party of China’s military-civil fusion strategy, which aims to leverage private firms in improving technologies that have defence applications.^[11] Thus, the year 2025 began with a jolt for Chinese tech companies with social media and gaming giant Tencent, and battery manufacturer Contemporary Amperex Technology Co., Ltd (CATL)^[b] designated as Chinese military companies operating in the US.^[12] Evidently, with each successive presidential administration, the technology curbs are getting tougher.

Beijing’s Assessment of Trump 2.0

Before Trump was re-elected in January 2025, apprehensions were already rife in both Chinese state-controlled media and official Communist Party communiques, even though he was never named directly in those documents. During China’s National People’s Congress and the Chinese People’s Political Consultative Conference in March 2023, Chinese President Xi Jinping stated that Western countries, led by the US, had implemented “comprehensive containment, encirclement and suppression against China” that presented challenges to its development.^[13] In May 2023, China’s Central National Security Commission warned of a difficult security environment ahead and called for preparations to combat “worst-case scenarios”.^[14] Chinese scholar Li Wei, from the China Institute of Contemporary International Relations, has interpreted this as a reference to “unilateral trade protection” and “regional and international conflicts”.^[15] During the Third Plenum of the 20^th Central Committee in July 2024, Xi argued that China’s industrial system remained underdeveloped and warned of attempts by a Western-led coalition to contain the country.^[16]

To counter the onslaught, the Communist Party elite agreed to further Chinese-style modernisation to upgrade industrial capacity in the Plenum resolution. It called for building resilience through “strong industrial chains” in sectors such as integrated circuits, industrial machine tools, medical equipment, and basic and industrial software.^[17] China also aimed to enhance the competitiveness of state-owned enterprises and infuse more capital in sectors with national security implications.

This sentiment of systematic suppression has resonated in a 2024 survey by the Center for International Security and Strategy (CISS), a security-focused think tank affiliated with Tsinghua University. Around 90 percent of respondents believed that the US was containing China’s development, and that America’s goal was to trigger ‘peaceful evolution’ in China.^[18] In the Chinese political lexicon, the theory of peaceful evolution (hépíng yǎnbiàn

^[和平演变]) denotes a strategy that combines economic measures, ideological subversion, and leveraging disaffected elements to overthrow the Communist Party of China.^[19]

Beijing sees unanimity on China policies between the Trump 1.0 and Biden administrations. While Trump had proposed “decoupling”—undoing the economic interdependence between the two countries—in the Biden era, the focus was on “derisking”, or building resilient supply chains.^[20] Yet, a May 2023 article published in Xinhua observed that derisking is not a watered-down decoupling but a rebranded campaign to align more allies in a broader effort to curb China’s growth and interfere in its internal affairs (again, implying efforts at regime change).^[21] As early as in 2023, Beijing anticipated that measures to contain China were likely to get more stringent. Zhang Zhixin, a scholar from the China Institute of Contemporary International Relations, argues that the Biden administration’s policy goal was to provoke a new Cold War. According to Zhang, America’s push for more intense confrontation stems from its deteriorating domestic political environment—since 2016, engagement with Beijing has been perceived as weak and politically incorrect, whereas a hawkish stance is more appropriate.^[22]

The paper argues that US defence and security policy has been manipulated by the military-industrial complex, especially since the war in Ukraine proved lucrative.^[23] Consequently, the arms companies have depicted Taiwan as the next Ukraine, amplifying the “China threat” narrative to drive arms sales in Asia.^[24] Chinese academics are particularly concerned about Trump 2.0, especially the composition of the new political elites. Su Liuqiang, from the Center for American Studies of the Shanghai Institutes for International Studies, notes that during Trump’s first term, Republican veterans filled key Cabinet roles since he did not have his own inner circle. In contrast, Trump 2.0 features key appointments from the MAGA (Make America Great Faction) faction—Vice President J.D. Vance, Secretary of Defense Peter Hegseth, Secretary of Homeland Security Kristi Noem, and Director of National Intelligence Tulsi Gabbard—giving Trump more leeway on his China policy.^[25]

Shi Guannan, from the Institute of American Studies of the China Institutes of Contemporary International Relations, warns that Trump’s criticism of China’s “unfair” trade practices and the US trade deficit with Beijing signalled correctly the possibility of higher tariffs, revocation of most-favoured-nation status, and a renewed China-US trade war.^[26] Consequently, in the field of science and technology, there is apprehension that the US under Trump could increase its technological containment of China, and even fast-track “technological decoupling” ^{[kējì tuōgōu (}科技脱钩)] between the two nations. While the Biden administration has bolstered export controls on sectors like artificial intelligence and semiconductors, Shi anticipates that Trump 2.0 could have a whole-of-government approach, intensifying sanctions across the board. Shi also points to possible leverage, citing Trump’s statement that tariffs are “a means, not an end”. This, he suggests, could open space for negotiations in finance and trade, including the use of China’s influence—possibly over Russia in bringing the war in Europe to a close, which has been Trump’s pledge. A perusal of Chinese-language sources demonstrates that the Party-state was alert to Trump’s political comeback and early on was preparing a toolkit, anticipating some of the actions under a Trump 2.0.

PRC’s Evolving Toolkit

China had introduced various countermeasures in response to the US’s aggressive position during Trump 1.0. Beyond retaliatory tariffs and currency depreciation, China’s response to US actions has centred broadly on four pillars: Unreliable Entities List (2019); Export Control Law (2020); Anti-Sanctions Law (2021); and the expansion of the Anti-Monopoly Law since 2024.

Unreliable Entities List, 2019

The ‘Unreliable Entities List’, introduced in 2019, seeks to penalise foreign firms that curtail business transactions with Chinese entities.^[27] Companies on the list may face import and export curbs, a ban on investment, and limitations on employee travel or entry into China. In February 2023, US defence contractors like Raytheon and Lockheed Martin were placed on the list—largely a symbolic move, as neither firm sells arms to China. However, Beijing also barred them from investing in China, banned their senior management from entering the country, and revoked residency permits for their employees.^[28]

Export Control Law, 2020

China introduced its own export control framework with the Export Control Law, which came into effect in December 2020. The law prohibits the export of advanced know-how and “strategic materials” to specific companies^[29] and allows the Chinese government to act against nations or regions that violate its national security or “interests”. Exports of controlled items require official clearance, with the Chinese entity required to provide the details of the end-user and evidence of the item’s final application. The insertion of the term ‘interests’ suggested that the regime would have more room to manoeuvre against entities it sought to penalise.

Ahead of the then US Secretary of the Treasury Janet Yellen’s visit to China in July 2023, Beijing retaliated by restricting the supply of strategic materials. It imposed export controls on critical metals like gallium and germanium, both essential to semiconductor and electronics manufacturing,^[30] with China producing 98 percent of gallium worldwide as of 2023.^[31] Notably, China signalled that this measure was a prelude to future actions. Wei Jianguo, a former Vice Minister of Commerce, warned that if restrictions on China’s access to advanced technology get tighter, countermeasures will also escalate.^[32]

As a top producer of rare-earth elements—a cluster of 17 metals used in space, weapons, and high-tech industries—Beijing has an advantage. Days after Trump’s 2024 election win, Beijing imposed export curbs on critical elements like tungsten, graphite, magnesium and aluminium alloys, used in electronic products, classifying them as “dual use”.^[33] Apart from their use in technology supply chains, they also have applications in building military equipment, arms, and spacecraft, and in the aviation sector. A European Union (EU) study found that China controls more than 80 percent of global tungsten extraction and processing and nearly 90 percent of global magnesium production.^[34]

In January 2025, China’s Ministry of Commerce announced its intention to curb the export of know-how related to lithium-ion battery production—a key component in electric automobiles and the global clean energy transition. It also aims to add extraction technology for gallium—an important element for semiconductor production—to the restricted export list that will require an export license.^[35] Additionally, in January 2025, Beijing directed mining firms operating abroad to declare information on both proven and prospective reserves of rare-earths, specifically items like titanium ore, zircon, tantalum ore, and antimony, whose export was banned by China in October 2024.^[36] Beijing’s curbs related to the export of rare-earths were extended to seven more minerals—samarium,  gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium—in April 2025.^[37] These minerals are critical ingredients in the production of special magnets, which are widely used in electric automobiles, clean-energy equipment and armament manufacturing.^[38]

Anti-Sanctions Law, 2021

In June 2021, China passed the Anti-Sanctions Law to protect its sovereignty, security, and development interests. It prohibits organisations and individuals—both nationals and overseas—from assisting in the enforcement of foreign measures deemed discriminatory against Mainland Chinese entities.^[39] The law also entitles those affected by such sanctions to the right to seek legal recourse for compensation. The legislation followed US actions targeting Chinese companies with alleged ties to the People’s Liberation Army (PLA) or alleged human rights violations.

In recent years, Chinese and Hong Kong officials have been sanctioned by Western nations for their role in repressing civil liberties in Hong Kong. The law empowers China to apply countermeasures against foreign nations whose actions “breach international law” or attempt to suppress China. The law outlines punitive actions such as visa denial, deportation, banning of financial transactions, closure of cooperation with Chinese entities, and asset seizure. Notably, sanctions were imposed against former US Commerce Secretary Wilbur Ross in July 2021, followed by sanctions on Miles Maochun Yu, who served as Principal China Policy Advisor on the Policy Planning Staff to Secretary of State Mike Pompeo, and Todd Stein, Deputy Staff Director of the Congressional-Executive Commission on China. Their kin faced sanctions that included a visa ban and a freeze on assets in China.

Anti-Monopoly Law, 2008

The Anti-Monopoly Law (AML), China’s first exhaustive antitrust legislation, came into effect in 2008 to regulate foreign multinationals operating on the mainland.^[40] While monopolistic behaviour in economic activities on the mainland comes under its ambit, the law seeks to curb entities that restrict competition within China’s domestic market, and thus its jurisdiction extends beyond the territory of the People’s Republic of China (PRC).^[41] In December 2024, Nvidia Corp.^[c] came under investigation, facing potential penalties of up to US$1 billion. The scope of the investigation by China’s State Administration for Market Regulation covers Nvidia’s corporate takeover of Israeli firm, Mellanox Technologies.^[42] Google became the latest target in February 2025, with regulators examining whether the dominance of its Android operating system affects Chinese mobile-phone manufacturers.^[43]

However, there are concerns that such “lawfare” could deter foreign investment. A survey by the American Chamber of Commerce in China (conducted between October-November 2024 before and after the US presidential election) found that nearly 30 percent of US firms were either considering relocating operations or had already begun doing so.^[44] Additionally, 21 percent no longer considered China a top priority for investment. This lawfare strategy demonstrates that China is hardening itself and has decided that it will prioritise national security over the economy in a confrontation against the US.

Conclusion

A close reading of Chinese domestic discourse shows that the Communist Party of China had been apprehensive about the return of Trump, and consequently, the continuation of his policies to counter China. At the time of writing, Trump 2.0 has had 100 days in office, and the Chinese establishment continues to be concerned about Trump’s actions that disrupt supply chains related to industrial inputs like semiconductors and machine tools, assessing its ultimate aim as dislodging the Communist Party of China from power.

In the past five years after Trump’s exit from the White House, China had been working to create a framework to institutionalise export-control measures, like the Export Control Law of 2020, to regulate the flow of sensitive material to other nations. The Unreliable Entity List, compiled in 2019, targets companies that restrict dealings with Chinese firms. This was followed by the Anti-Foreign Sanctions Law of 2021 that builds the mechanism for acting against officials of foreign nations, their kin, and expanding that to the ecosystem like non-profits and think tanks that provide counsel to foreign governments against China.

Trump’s first term saw a trade war with China, in which Beijing responded with retaliatory tariffs and currency depreciation. Since 2020, however, China has started work on installing an export-control framework and instituted anti-monopoly inquiries targeting companies particularly in the tech sector—signalling its intent to leverage its dominance in critical elements. With rare-earths being critical inputs in chips, electronics manufacturing, electric vehicles, energy production, and defence, America Inc has presaged disruptions and sector-wide impact triggered by Beijing’s restrictions.^[45] Thus, China’s aim is to exploit America’s supply chain vulnerabilities as bargaining chips in future negotiations with Trump.

Endnotes

^[a] In the first tier are 18 countries—Australia, Belgium, Canada, Denmark, Finland, France, Germany, Ireland, Italy, Japan, the Netherlands, New Zealand, Norway, Republic of Korea, Spain, Sweden, Taiwan, and the United Kingdom—which are exempt from the rules. In the second tier is India that faces a cap on the amount of computing power that can be imported from American firms; and Iran and Syria in the third tier are barred from accessing the technology. Additionally, there is a general validated end-user clause that includes India and China. Under this, Indian entities that obtain this authorisation can deploy the exported items for civilian and military uses, not nuclear purposes. With this authorisation, Chinese firms, on the other hand, can only apply the technology for civilian use.

^[b] CATL is reputedly one of the world’s largest battery makers, while Tencent operates a mega-app ‘WeChat’ that combines communications, digital-cash remittance, social networking, transportation, and meal delivery with a user-base of nearly a billion. The tech conglomerate’s interests span the spheres of finance, cloud computing, media, messaging, video-streaming, and cinema production.

^[c] A big producer of graphics processing units.

^[1] Bob Davis and Lingling Wei, Superpower Showdown (Harper Business, 2020), pp. 54.

^[2] The White House, National Security Strategy of the United States, December 2017, Washington DC, 2017, https://trumpwhitehouse.archives.gov/wp-content/uploads/2017/12/NSS-Final-12-18-2017-0905.pdf.

^[3] “National Security Strategy of the United States”

^[4] Department of Commerce, United States Government, “The Clean Network,” https://www.commerce.gov/news/press-releases/2020/05/commerce-addresses-huaweis-efforts-undermine-entity-list-restricts

^[5] U.S. Department of State, United States Government, https://2017-2021.state.gov/the-clean-network/#:~:text=To%20prevent%20U.S.%20citizens'%20most,%2C%20China%20Mobile%2C%20China%20Telecom%2C

^[6] U.S. Department of State, United States Government, https://2017-2021.state.gov/the-clean-network/#:~:text=To%20prevent%20U.S.%20citizens'%20most,%2C%20China%20Mobile%2C%20China%20Telecom%2C

^[7] The White House, United States Government, “Remarks by National Security Advisor Jake Sullivan at the Special Competitive Studies Project Global Emerging Technologies Summit,” https://bidenwhitehouse.archives.gov/briefing-room/speeches-remarks/2022/09/16/remarks-by-national-security-advisor-jake-sullivan-at-the-special-competitive-studies-project-global-emerging-technologies-summit/

^[8] Department of Commerce, United States Government,  https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3158-2022-10-07-bis-press-release-advanced-computing-and-semiconductor-manufacturing-controls-final/file

^[9] U.S. Department of Commerce, United States Government, https://www.bis.gov/press-release/commerce-strengthens-restrictions-advanced-computing-semiconductors-enhance-foundry

^[10] Department of Commerce, United States Government, “Framework for Artificial Intelligence Diffusion,” January 15, 2015, https://www.federalregister.gov/documents/2025/01/15/2025-00636/framework-for-artificial-intelligence-diffusion

^[11] Department of Commerce, United States Government, https://public-inspection.federalregister.gov/2025-00070.pdf

^[12] Department of Commerce, United States Government, https://public-inspection.federalregister.gov/2025-00070.pdf

^[13] “习近平在看望参加政协会议的民建工商联界委员时强调 正确引导民营经济健康发展高质量发展 [Xi Jinping Meets Joint Committee on Civil Engineering and Construction and Industry and Commerce Members],” CCTV, March 6, 2023, https://tv.cctv.com/2023/03/06/VIDEI1C7epPnU4bmFDmWh9MC230306.shtml

^[14] “习近平主持召开二十届中央国家安全委员会第一次会议强调 加快推进国家安全体系和能力现代化 以新安全格局保障新发展格局 [Xi Presides over National Security Commission Meeting, Emphasising Need to Accelerate National-security System Modernisation, and Ensure New Development Pattern with a New Security Pattern],” Xinhua, May 30, 2023, http://www.news.cn/politics/leaders/2023-05/30/c_1129657348.htm

^[15] “Xi Urges Accelerated Efforts to Modernize National Security System, Capacity,” Global Times, May 31, 2023, https://www.globaltimes.cn/page/202305/1291669.shtml

^[16] Xi Jinping, “习近平：关于《中共中央关于进一步全面深化改革、推进中国式现代化的决定》的说明-新华网, [Explanation of Decision of the Communist Party of China Central Committee on Comprehensively Deepening Reform and Promoting Chinese-style Modernisation],” Xinhua, July 21, 2024, http://www.news.cn/politics/leaders/20240721/ded6316ad77344cf9a2a45463ec1288b/c.html

^[17] “受权发布丨中共中央关于进一步全面深化改革　推进中国式现代化的决定-新华网 [Decision of the Communist Party of China Central Committee on Comprehensively Deepening Reform and Promoting Chinese-style Modernisation],” Xinhua, July 21, 2024 http://www.news.cn/politics/20240721/cec09ea2bde840dfb99331c48ab5523a/c.html

^[18] Da Wei et al., Chinese Outlook on International Security, Beijing, 2024, https://ciss.tsinghua.edu.cn/upload_files/atta/1727662169826_AD.pdf.

^[19] “Peaceful Evolution,” The Center for Strategic Translation, https://www.strategictranslation.org/glossary/peaceful-evolution.

^[20] White House, Unites States Government, https://www.whitehouse.gov/briefing-room/speeches-remarks/2023/04/27/remarks-by-national-security-advisor-jake-sullivan-on-renewing-american-economic-leadership-at-the-brookings-institution/.

^[21] “新华时评：炮制对华“去风险”是“脱钩论”新瓶旧酒——起底美国抹黑中国话术系列评论之 [Derisking Against China is New Bottle of Old Wine],” Xinhua, May 25, 2023, http://www.news.cn/world/2023-05/25/c_1129644030.htm

^[22] Zhang Zhixin, “张志新：布林肯访华，为中美恢复对话提供机遇_言论 [The Visit of Antony Blinken and the Issue of China-US Dialogue],” CFISNET.com, June 19, 2023, http://comment.cfisnet.com/2023/0619/1328101.html.

^[23] Zhixin, “张志新：布林肯访华，为中美恢复对话提供机遇_言论 [The visit of Antony Blinken and the issue of China-US dialogue]”

^[24] Zhixin, “张志新：布林肯访华，为中美恢复对话提供机遇_言论 [The visit of Antony Blinken and the issue of China-US dialogue]”

^[25] Su Liuqiang, “苏刘强：忠诚、非主流的“工具人”或加剧特朗普2.0“回音壁效应 [“Yes-men May Exacerbate Trump 2.0’s "Echo-wall Effect"],” CFIsnet.com, November 29, 2024, http://comment.cfisnet.com/2024/1129/1330874.html.

^[26] Shi Guannan, “特朗普的“新班底”都有什么人，将如何影响世界 [Who are Trump's New Team and How Will It Affect the World?],” CFIsnet.com, Dec 2, 2024, http://comment.cfisnet.com/2024/1202/1330879.html.

^[27] Ministry of Commerce, The People’s Republic of China, http://www.mofcom.gov.cn/article/i/jyjl/e/201905/20190502868927.shtml

^[28] “我国将洛克希德·马丁公司、雷神导弹与防务公司列入不可靠实体清单 _中国经济网——国家经济门户,” CE.CN, February 16, 2023,  http://www.ce.cn/xwzx/gnsz/gdxw/202302/16/t20230216_38397247.shtml.

^[29] Ministry of Commerce, The People’s Republic of China, http://exportcontrol.mofcom.gov.cn/article/zcfg/gnzcfg/flfg/202111/226.html

^[30] Ministry of Commerce, The People’s Republic of China, http://www.mofcom.gov.cn/article/zcfb/zcdwmy/202307/20230703419666.shtml

^[31] U.S. Geological Survey, United States Government, https://doi.org/10.3133/mcs2024.

^[32] Ma Si, “Former Vice-minister of Commerce: China Has More Tools for Countermeasures Against US Export Controls,” China Daily, July 5, 2023, https://www.chinadaily.com.cn/a/202307/05/WS64a4ca73a310bf8a75d6d545.html.

^[33] Ministry of Commerce, The People’s Republic of China, https://www.mofcom.gov.cn/xwfb/xwfyrth/art/2024/art_e1930a8010fe4ef8a2a2c89df1a7b812.html

^[34] European Union Factsheet, https://scrreen.eu/wp-content/uploads/2024/01/SCRREEN2_factsheets_TUNGSTEN-update2.pdf; Call on EU Policymakers to Address Imminent Supply Shortage of Chinese Magnesium/Position paper, September 27, 2021, https://european-aluminium.eu/wp-content/uploads/2022/08/2021-09-27-position-paper_impact-of-imminent-short-1.pdf.

^[35] Lu Yutong & Han Wei, “China to Restrict Exports of Lithium Battery Technologies,” Caixin, January 3, 2025,

https://www.caixinglobal.com/2025-01-03/china-to-restrict-exports-of-lithium-battery-technologies-102275380.html.

^[36] Mia Nulimaimaiti, “Beijing Orders Chinese Miners to Report More of Their Overseas Reserves,” SCMP, January 4, 2025, https://www.scmp.com/economy/china-economy/article/3294080/beijing-orders-chinese-miners-report-more-their-overseas-reserves.

^[37] Ministry of Commerce, The People’s Republic of China, https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_9c2108ccaf754f22a34abab2fedaa944.html

^[38] Kenji Kawase, “Ford Warns of Industry Vulnerability to China Rare-earth Restrictions,” Nikkei Asia, May 6, 2025, https://asia.nikkei.com/Business/Automobiles/Ford-warns-of-industry-vulnerability-to-China-rare-earth-restrictions

^[39] National People’s Congress, The People’s Republic of China, http://www.npc.gov.cn/npc/c30834/202106/d4a714d5813c4ad2ac54a5f0f78a5270.shtml

^[40] National People’s Congress, The People’s Republic of China, http://www.npc.gov.cn/zgrdw/englishnpc/Law/2009-02/20/content_1471587.htm.

^[41] National People’s Congress, The People’s Republic of China, http://www.npc.gov.cn/zgrdw/englishnpc/Law/2009-02/20/content_1471587.htm.

^[42] “英伟达涉嫌违反反垄断法 市场监管总局依法决定立案调查-新华网,” News.cn, December 9, 2024, http://www.news.cn/fortune/20241209/9fa0876a6acb48219877ad047a3bacd8/c.html

^[43] “谷歌公司涉嫌违反反垄断法 市场监管总局依法决定立案调查-新华网,” News.cn, February 4, 2025,

http://www.news.cn/fortune/20250204/b375a49abc9543ddbab5b09d3f0cb172/c.html

^[44] Claire Ma et al., China Business Climate Survey Report, Beijing, American Chamber of Commerce in China, 2024, https://www.amchamchina.org/china-business-climate-survey-report/.

^[45] Kawase, “Ford Warns of Industry Vulnerability to China Rare-earth Restrictions”

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