On February 4, 2025, when U.S. tariffs on goods produced by China increased by 10% (see Thompson Hine Update of February 3, 2025 and Federal Register Notice), China responded by undertaking several retaliatory trade and tariff actions. These actions include:
- Implementing a 15% tariff on U.S. coal and liquefied natural gas, and a 10% tariff on crude oil, agricultural machinery, cars and pickup trucks;
- Establishing export controls on more critical minerals;
- Adding two U.S. companies to its unreliable entities list; and
- Initiating an antimonopoly investigation into Google.
The tariffs were announced by China’s Customs Tariff Commission of the State Council and will begin on February 10, 2025. See China Ministry of Finance, Tariff Announcement No. 1 of 2025. In announcing the tariffs, the Commission stated: “The US’ unilateral practice of imposing such additional tariffs has seriously violated the World Trade Organization rules” and, accordingly, China will challenge the most recent U.S. tariffs at the WTO.
China’s Ministry of Commerce also imposed export controls on tungsten, tellurium, bismuth, molybdenum and indium. While not implementing a full ban on the export of these critical minerals, China will now require licenses to export 20 of these critical mineral-related products to “safeguard national security interests.” See China Ministry of Commerce, Announcement No. 10 of 2025. In addition, a U.S. clothing company and a biotechnology company were placed on China’s Unreliable Entities List for “violat[ing] the principle of normal market transactions, interrupt[ing] normal transactions with Chinese enterprises, and [taking] discriminatory measures against Chinese enterprises, seriously harming the legitimate rights and interests of Chinese enterprises.” See China Ministry of Commerce, Security and Control Directorate, Announcement 2025 No. 4. Placement on this list can trigger various restrictive or prohibitive measures, including import/export or investment restrictions. China’s State Administration for Market Regulation also announced that it was opening an antimonopoly investigation into a major U.S. technology company, Google.