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As tensions between D.C. and Beijing escalate, management teams are looking to better understand and reduce their exposures to the U.S.-China trade war. As of mid-April 2025, we offer a review of China’s non-tariff countermeasures that target the U.S. With an unclear off-ramp for either side, management teams will have to further build scenarios that offer greater supplier optionality in the short-term while also re-evaluating long-term enterprise strategy. Overall, the cost of doing business in and with China will increase for U.S. business and will likely have lasting impact. How can businesses manage through China’s escalating retaliation?
Key takeaways:
- China has aggressively amplified its retaliatory measures in response to President Trump’s retooling of U.S. trade policy
- While both countries are imposing duties over 100% on one-another, China’s countermeasures that are non-tariff require close understanding by management teams, as they signal long-term risk factors to a U.S. company’s enterprise strategy
- Analysts expect a long road of increasing tensions, with a resulting potential for further increases to duties, greater restrictions on critical mineral exports, as well as other approaches taken by the Chinese Ministry of Commerce
- S. companies will have to ramp up their supplier diversification and Know Your Supply Chain (KYSC) strategies to hedge against growing uncertainty and material disruptions to their businesses
Retaliatory tariffs on the rise
Tariff-related escalations continue to capture media and analyst attention, non-tariff measures from China also demonstrate Beijing’s weight and intent to stand up to the Trump administration. Tariff duties have risen sharply since February, as depicted in the figure below.
At the time of writing, the U.S. is imposing 145% duties on Chinese imports to the U.S., while China is imposing 125% tariffs on U.S. imports to China.
China’s portfolio of non-tariff countermeasures continues to expand
As China flexes the might of its industrial supply chain and economy, Beijing continues to roll-out a list of non-tariff countermeasures to further restrict trade between the U.S. and China.
Extend countermeasures to countries making deals with the U.S. For countries that strike trade deals with the U.S. at “Beijing’s expense,” China has threatened to take additional countermeasures against them directly
- Why this matters -> With this latest announcement, global financial markets continue to react negatively, and countries will feel more pressure to “pick sides” and the +50 bilateral discussion that U.S. Trade Representative Jamieson Greer has mentioned will be of higher stakes
Antitrust Probe. A number of U.S. companies have been identified by China’s antitrust regulator, most notably Google and Nvidia. If found guilty, significant fines or other regulatory actions may result
- Why this matters -> With a growing number of U.S. businesses reducing their operations China, citing challenging operational contexts, this new measure towards large U.S. businesses makes the Chinese market less attractive and may deter future investment
Export controls. China’s commerce ministry has grown its export control restrictions on 15 U.S. defense-related companies that currently restrict Chinese suppliers, and for some that engage with Taiwan
- Why this matters -> Even if the recently banned companies don’t operate in China, many have supply chains reliant on China, which could cause operational disruptions
Critical minerals, rare earths. As a signal to high-tech companies, China has imposed restrictions on five types of critical minerals, special magnets, and seven rare earth minerals (samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium)
- Why this matters -> The U.S. has a material reliance on China for many raw materials and critical minerals. For rare earths, China accounts for 72% of all imports
U.S. import suspensions. Import qualifications for three U.S. soybean exporters have been suspended, alongside imports of U.S. forestry products
- Why this matters -> About half of U.S. soybean exports are shipped to China, totaling nearly $12.8 billion in trade in 2024. China is one of the world’s largest importers of wood products and third largest destination for U.S. lumber
Unreliable entity list. China’s Commerce Ministry has announced that ten additional U.S. companies have been added to the unreliable entity list; this means these firms are prohibited from exporting or importing in China or from making new investments in the country
- Why this matters -> U.S. companies operating in China may feel greater pressure to demonstrate more caution in their evaluation of suppliers, product strategy, and external communications. For those in defense or defense-related, additional restrictions may be imposed
TikTok. Beijing has walked back its earlier approval for a U.S.-majority-owned TikTok deal until tariff and trade disputes are resolved
- Why this matters -> Less so for large U.S. multinationals, instead this is a symbolic battle rather than something that will be operationally material
WTO complaints. China filed formal complaints with the World Trade Organization (WTO) regarding the legality of U.S. tariff policy and has called it “typical unilateral bullying.” China claims that U.S. measures are inconsistent with the U.S.’s obligations under provisions under the General Agreement on Tariffs and Trade (GATT) 1994
- Why this matters -> The WTO has been discredited over the years for its failure to enforce previous GATT violations. Even if deemed “illegal” after consultation, the Trump administration may not face penalties or blockers in implementing its current trade agenda (which violates trade rules and norms)
Anti-circumvention investigation. China has made history by launching an investigation into the circumvention of the anti-dumping duty order on U.S. fiber-optical products. This type of investigation is widely used by WTO members to ensure the effectiveness of trade remedy measures
- Why this matters -> China is looking to leverage existing mechanisms to demonstrate to broader trade partners that it is operating in good faith and can be a trusted partner. Especially in the scenario of ASEAN countries having to “pick sides,” the Chinese Ministry of Commerce is eager to demonstrate that it respects WTO authority
Will more Chinese countermeasures come?
At this point, the uncertainty around where the escalating trade war will end remains as high as ever. Although certain scenarios may be pointing to the end-game for the Trump administration, there may be other measures taken by China. Given that the U.S. has a large dependence on China for critical minerals, many anticipate this dimension to be most potentially damaging to the U.S. economy and one that China can continue to leverage to exert its influence.
Actions management teams can take:
- Increase the cadence of operational risk evaluation
- Plan many geopolitical scenarios and risk events and do so more often
- Ramp up supplier diversification and Know Your Supplier (KYS) strategy
- Engage full enterprise in assessing exposure to Chinese suppliers, resources, and China-based operations
- Develop financial contingencies for increased cost of goods sold
- Broaden definition of enterprise political risk to include dimensions critical to President Trump’s whole-of-government national security agenda
- Engage with public affairs team to bolster pre-competitive shared advocacy strategy with peer organizations and industry association
Questions for management teams:
- To what extent do we have immediate operational exposure in China? What is the magnitude of fixed assets currently at play in China? To what extent are our supply chain and suppliers exposed to Chinese non-tariff countermeasures?
- What do we expect the increased financial burden to be as a result of Chinese non-tariff countermeasures?
- How can we better anticipate future additions to China’s non-tariff countermeasure portfolio?
- To what extent are our products and services reliant on critical mineral imports? To what extent would a critical mineral import disruption impact our operations and financial projections?
- What leverage, if any, do we have to engage in pre-competitive advocacy with industry peers to request policy changes, exemptions, etc.?
- What long-term planning have we done to extract our enterprise out of China? Out of ASEAN?
Additional Telesto resources:
- Navigating shifting political risk under Trump 2.0 – how companies are staying ahead
- Tariff endgame, economic powerplay or political gamble?
- Know your supplier – Diversifying comes with risk amidst escalating trade wars
- Atlas, equips your organization’s leaders with the insights and knowledge necessary to stay up to date, mitigate risks, and seize business opportunities associated with sustainability, climate, and ESG
- Prism, our ESG benchmarking tool, helps your organization to rapidly strengthen its sustainability, climate, and ESG performance and disclosures through in-depth benchmarking of industry peers and identification of gaps and areas of distinction
- Recently released by Telesto Strategy’s CEO & Founder, Alex Kruzel, The Courage to Continue: Stay the Course on Sustainability to Secure our Future, explores the connection between corporate priorities and President Trump’s national security agenda