China Temporarily Suspends Export Controls and Unreliable Entity List Measures Against U.S. Companies for 90 Days

On May 12, 2025, President Donald Trump signed an executive order significantly lowering the “reciprocal tariffs” imposed on Chinese goods for a 90-day period, beginning May 14. This move reflects the United States’ commitment under the Joint Statement on the U.S.-China Economic and Trade Talks in Geneva. In response, China announced a 90-day suspension of certain non-tariff countermeasures targeting U.S. entities, focusing on export controls and the Unreliable Entity List.

These parallel actions signal a temporary de-escalation of trade tensions between the two countries and create a narrow window for businesses impacted by the bilateral restrictions to reassess compliance and explore renewed commercial activity.

For legal guidance on how these developments may affect your operations, please contact the ILS team at contact@consultils.com.

Export Controls Temporarily Suspended — Licensing Still Required

In April 2025, China’s Ministry of Commerce designated 28 U.S. entities on its export control list, restricting their ability to import dual-use items—technologies and equipment that have both civilian and military applications.

Under the new arrangement:

• As of May 14, the export control measures are suspended for 90 days;

• During this suspension, Chinese exporters seeking to transact with these entities must still submit formal license applications to the Ministry;

• Approvals will be granted on a case-by-case basis, consistent with applicable Chinese laws and regulations.

Although restrictions are paused, export license procedures remain in effect. Compliance obligations have not been waived.

Unreliable Entity List Measures Suspended — Prior Approval Still Required

In early April, China added 17 U.S. companies to its Unreliable Entity List, restricting their ability to engage in import/export activities and make new investments in China under the Regulations on the Unreliable Entity List and the Anti-Foreign Sanctions Law.

Effective May 14:

• These restrictions are suspended for 90 days;

• Chinese businesses intending to resume transactions or investments with the listed U.S. entities must apply for approval;

• The Unreliable Entity List Working Mechanism will evaluate and approve eligible transactions.

Cooperation may resume, but prior approval is mandatory—transactions without clearance remain prohibited.

Strategic Pause, Not a Policy Shift

This coordinated suspension of tariffs and regulatory countermeasures offers temporary relief for affected businesses and sectors. However, it does not signal a permanent shift in policy. Several risks and uncertainties remain:

• These are temporary suspensions. There is no guarantee of extension, and measures may be reinstated without further notice;

• Future trade policy developments will depend heavily on progress in areas such as fentanyl control and supply chain security;

• The U.S. continues to pursue Section 232 investigations, which could result in new restrictions;

• China’s export controls on heavy rare earth elements—critical for advanced manufacturing and defense industries—remain in place.

  
  

This 90-day period presents a limited but valuable opportunity for businesses to revisit paused transactions, update risk assessments, and evaluate regulatory exposure.

For legal guidance on how these developments may affect your operations, please contact the ILS team at contact@consultils.com.

Disclaimer: The materials provided on this website are for general informational purposes only and do not, and are not intended to, constitute legal advice. You should not act or refrain from acting based on any information provided here. Please consult with your own legal counsel regarding your specific situation and legal questions.

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Fiona Xu, Esq. is the Partner and Head of Transaction of ILS.

She has extensive experience supporting global and high-growth technology companies on compliance and business needs. Her practice focuses on regulatory compliance across different sectors, with a focus on sector-specific regulations for artificial intelligence (AI) and medical devices. She supports multinational corporations in establishing and maintaining U.S. operations, managing legal and compliance challenges in various areas such as Privacy, Export Control, and CFIUS issues.

Email: contact@consultils.com | Phone: 626-344-8949