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U.S. vs. China: Where Does American Market Access to China Stand Today?

Last Update: 15 May 2025, 1:30 pm CET

This blog provides a factual inventory of all unilateral measures China has enacted toward the United States during the last four months that remain in force as of the writing date. It follows the U.S.-China joint announcement on 12 May 2025.

Authors

Fiama Angeles, Marius Risse

Date Published

12 May 2025

Latest Updates (15 May 2025)

The blog has been updated to incorporate:

China's confirmation of the 90-day suspension of all U.S. entity blacklistings announced after 2 April 2025

TL;DR: What recent Chinese restrictions on the U.S. are still in force today?

Since 20 January 2025, the Chinese government has announced several new restrictions on the U.S. which remain in force today:

1. Additional 10% in Response to Reciprocal Tariffs: China committed to cutting additional duties on U.S. imports from 125% to 10%. This temporary 90-day measure follows U.S.-China negotiations in Geneva.

2. Additional 10% or 15% in Response to Fentanyl Tariffs: Since February and March 2025, China imposed additional tariffs of 10% or 15% on selected US products in two rounds of countermeasures to US fentanyl-linked additional tariffs. The affected US products include coal, coke, LNG, selected vehicles, and various agricultural products.

3. Critical Minerals Export Controls: In February 2025, export controls were established for tungsten, tellurium, bismuth, molybdenum, and indium, which are essential for semiconductor and high-tech manufacturing. These restrictions were expanded in April 2025 to cover medium and heavy rare earth elements including samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium.

4. U.S. Entity Blacklisting before April 2025: Over 20 U.S. companies added to China's Unreliable Entity List and Export Control List in February and March 2025. Targeted companies operate in the aerospace, defence, drone manufacturing, and advanced technology sectors.

Furthermore, these actions have appeared in various reports, although they have not been officially confirmed by the Chinese government:

5. Selective Tariff Exemptions: Prior to the 12 May joint U.S.-China announcement, reports emerged that the Chinese government had created "whitelists" of certain U.S. products that would be exempted from countermeasures to the "reciprocal tariffs".

6. Chinese Investment Halt: China reportedly instructed branches to cease registration and approval for Chinese firms seeking U.S. investments as of 2 April 2025. This effectively restricts all Chinese outward investment to the U.S..

7. Boeing Delivery Suspension: In late April 2025, Boeing CEO Kelly Ortberg confirmed that Chinese airlines had stopped accepting new Boeing deliveries. On 13 May 2025, reports of the measure being lifted by Chinese authorities emerged.

In addition, future restrictions might be imposed under:

1. New Trade Defence Investigations: In April 2025, China initiated an antidumping investigation on imports of certain medical CT tubes from India and the United States.

2. Industry Competitiveness Investigations: Alongside the antidumping investigation, an Industry Competitiveness Investigation was launched for imported medical CT tubes.

3. 90-Day Suspension of U.S. Entity Blacklistings since April 2025: On 14 May 2025, China confirmed a 90-day suspension of all U.S. entity blacklistings announced after 2 April 2025. The restrictions may be reinstated if negotiations with the U.S. prove unsuccessful.

NB: The Joint Statement also included China's commitment to "adopt all necessary administrative measures to suspend or remove the non-tariff countermeasures taken against the United States since April 2, 2025." However, as the statement neither specified which non-tariff measures are covered nor has China officially announced implementation details at the time of writing, this blog continues to document all unilateral non-tariff measures for which China has not announced removal or suspension.

The details about which Chinese restrictions on the U.S. are still in force today

Chinese Government Actions With Official Announcements

1. Additional 10% in Response to Reciprocal Tariffs

12 May 2025: After meeting with U.S. counterparts in Geneva, the Chinese government committed to reducing the additional duties on imports from the U.S. from 125% to 10% for "an initial period of 90 days".

2. Additional 10% or 15% in Response to Fentanyl Tariffs

3 March 2025: China extended additional tariffs of 10% or 15% on various US agricultural products covered under 740 eight-digit tariff lines, also in response to the U.S. fentanyl-linked additional tariffs.
4 February 2025: China enacted additional tariffs on various US imports under 80 eight-digit tariff lines. The measure adds a 15% tariff on coal and liquefied natural gas as well as of 10% tariff on crude oil, agricultural machinery, large-displacement cars and pickup trucks. The tariffs were adopted as countermeasures to U.S. fentanyl-linked additional tariffs.

3. Critical Minerals Export Controls

4 April 2025: The Chinese Ministry of Commerce enacted new export controls on several medium and heavy rare earth items related to samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium.
4 February 2025: The Chinese Ministry of Commerce enacted new export controls on various critical minerals related to tungsten, tellurium, bismuth, molybdenum and indium.

4. U.S. Entity Blacklisting

4 March 2025: The Chinese Ministry of Commerce added U.S.-based Leidos, Gibbs&Cox, Inc, IP Video Market Info Inc, Sourcemap Inc, Skydio Inc, Rapid Flight LLC,Red Six Solutions, Shield AI Inc, HavocAI, Neros Technologies, Group W, Aerkomm Inc, General Atomics Aeronautical Systems Inc, General Dynamics Land Systems, and Aero Vironment to its Export Control List.
4 March 2025: The Chinese Ministry of Commerce added U.S.-based TCOM, Stick Rudder Enterprises LLC, Teledyne Brown Engineering Inc, Huntington Ingalls Industries Inc, S3 AeroDefense, Cubic Corporation, TextOre, ACT1 Federal, Exovera, and Planate Management Group to its Unreliable Entity List.
4 February 2025: The Chinese Ministry of Commerce added U.S.-based PVH Group and Illumina Inc to its Unreliable Entity List.

Chinese Government Actions Without Official Announcements

5. Selective Tariff Exemptions

Prior to the 12 May joint U.S.-China announcement, reports emerged that the Chinese government had created "whitelists" of certain U.S. products that would be exempted from the additional tariffs, allegedly after consulting with domestic companies. While the exempted goods were said to include semiconductors, pharmaceuticals, or aircraft engines, there were no official confirmations on how many and which products were exempted.

6. Chinese Investment Halt

2 April 2025: China reportedly instructed its branches to halt registration and approval for Chinese firms seeking to invest in the U.S., effectively restricting Chinese investment in America.

7. Boeing Delivery Suspension

13 May 2025: Bloomberg reported that the Chinese government allowed the resumption of US aircraft deliveries. The measure was reportedly adopted following the 12 May U.S.-China joint statement but is pending confirmation from other involved parties.
April 2025: The Chinese government reportedly ordered Chinese airlines not to take new deliveries from Boeing.

What to keep an eye out for

1. New Trade Defence Investigations

4 April 2025: China initiated an antidumping investigation on imports of certain medical CT tubes from India and the United States (HS code 9022.30.00).

2. Industry Competitiveness Investigations

4 April 2025: The Ministry of Commerce also initiated an Industry Competitiveness Investigation into imported medical CT tubes (HS code 9022.30.00). The investigation could lead to unspecified policy recommendations to enhance the industry’s competitiveness and reduce reliance on imports.

3. 90-Day Suspension of U.S. Entity Blacklistings since April 2025

14 May 2025: A Ministry of Commerce spokesperson confirmed a 90-day suspension of all U.S. entity blacklistings that were announced after 2 April 2025. This action temporarily halts the addition of 17 US firms to the Unreliable Entity List and of 28 US firms to the Export Control List. The restrictions may be reinstated if negotiations with the U.S. prove unsuccessful.

The suspension specifically covers:

9 April 2025: MOFCOM added U.S.-based Shield AI Inc, Sierra Nevada Corporation, Cyberlux Corporation, Edge Autonomy Operations LLC, Group W, and Hudson Technologies Co to its Unreliable Entity List.
9 April 2025: MOFCOM added U.S.-based American Photonics, Novotech Inc, Echodyne, Marvin Engeering Company Inc, Exovera, Teledyne Brown Engineering Inc, BRINC Drones Inc, SYNEXX U.S. Inc, Firestorm Labs Inc, Kratos Unmanned Aerial Systems Inc, Domo Tactical Communications; and Insitu Inc to its Export Control List.
4 April 2025: MOFCOM added U.S.-based Skydio Inc, BRINC to its Drones Inc, Red Six Solutions, SYNEXX U.S. Inc, Firestorm Labs Inc, Kratos Unmanned Aerial Systems Inc, HavocAI, Neros Technologies, Domo Tactical Communications, Rapid Flight LLC, and Insitu Inc to its Unreliable Entity List.
4 April 2025: MOFCOM added U.S.-based High Point Aerotechnologies, Universal Logistics Holdings Inc, Source Intelligence, Inc, Coalition For A Prosperous America, Sierra Nevada Corporation, Edge Autonomy Operations LLC, Cyberlux Corporation, Hudson Technologies Co, Saronic Technologies, Inc, Oceaneering International Inc, Stick Rudder Enterprises LLC, Cubic Corporation, S3 AeroDefense, TCOM, Limited Partnership, TextOre, and ACT1 Federal to its Export Control List.

This blog will be updated on an ongoing basis.