EXPORT CONTROLS | 2025-12-16

China's Historic Extraterritorial Export Controls: First-Ever Use of Foreign Direct Product Rule on Rare Earths Creates New Compliance Paradigm for California Importers

Understanding China's Unprecedented FDPR Mechanism, December 2025 Military Affiliation Restrictions, and Strategic Implications for California Technology, Defense, and Electric Vehicle Industries

On October 9, 2025, China's Ministry of Commerce (MOFCOM) issued Announcement No. 61 of 2025, marking a watershed moment in international trade law. For the first time in history, China deployed the Foreign Direct Product Rule (FDPR)—a mechanism previously wielded exclusively by the United States—to assert extraterritorial jurisdiction over rare earth elements and products derived from Chinese materials or technologies. This unprecedented expansion of China's export control regime, which escalat

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