1. Introduction

This section discusses the historical evolution and current characteristics of U.S. export control policies targeting Chinese high-tech enterprises. In 2020, the Trump administration abolished the License Exception for Civil End Users (CIV) for China, marking the beginning of a stringent phase in U.S. export controls toward China. After taking office, the Biden administration further intensified these policies, including frequent use of the Commerce Department’s Entity List, the enactment of the CHIPS and Science Act to restrict China’s access to advanced technology products, and economic sanctions on Xinjiang under the pretext of human rights. The Biden administration has also allied with partners to engage in comprehensive strategic competition with China, erecting a "small yard, high fence" approach and strengthening multilateral sanctions against China based on the Wassenaar Arrangement. The Russia-Ukraine conflict has solidified the U.S.-led "alliance of democracies," promoting multilateral cooperation under new circumstances. While imposing comprehensive economic sanctions on Russia, the U.S. and its allies have also intensified joint export controls against China in areas such as semiconductors, attempting a "hard decoupling" from China in critical technology sectors. The harm of multilateral export controls exceeds that of unilateral U.S. actions, and their targeted impact on Chinese high-tech enterprises and industries cannot be underestimated. This paper traces the history of U.S. export controls against China through the lens of the Coordinating Committee for Multilateral Export Controls (CoCom), examines the new characteristics and future trends of U.S.-led multilateral export control policies against China under the "new Cold War mentality," explores their impact on Chinese high-tech enterprises and the broader industry, and provides insights and foundations for China’s countermeasures and strategic planning.

2. The Strength of U.S. Export Controls Against China Is Determined by Bilateral Relations

This section discusses the influence of U.S.-China bilateral relations on U.S. export control measures. During the Cold War, the U.S. imposed the strictest export controls on China through CoCom to limit the flow of advanced technology to socialist countries. After the establishment of diplomatic relations, U.S. export controls on China loosened, particularly under the Reagan administration, when China was designated a "friendly non-allied country," leading to further relaxation. In the context of globalization, the U.S. sought a balance between political interests in strategic competition and economic losses, resulting in fluctuating export controls. As China’s comprehensive national power grew, U.S.-China relations entered a phase of strategic competition, prompting the U.S. to strengthen export controls as a key means of maintaining technological superiority and national security. The intensity of U.S. export controls against China is closely tied to the strategic positioning of bilateral relations and is implemented under U.S.-led multilateral frameworks.

3. The Return of "CoCom Cold War Mentality" and the Multilateralization of Export Controls Against China in the Context of Great Power Competition

Under the Biden administration, the U.S. has exhibited a clear "new Cold War mentality" amid great power competition, viewing China as its most pressing challenge and adopting a series of confrontational policies. These include expanding sanctions lists targeting Chinese entities, strengthening financial sanctions, restricting China’s access to foreign advanced technology, and politicizing issues related to Xinjiang to constrain China’s economic development. The U.S. has also revoked Hong Kong’s free port status, restricted investments by U.S. and allied companies in China, and sought to exclude China from global supply chains.

The U.S.-led multilateral export controls against China exhibit characteristics of a "new CoCom," isolating China in critical technology sectors through alliance-based organizations and depriving China of a voice in emerging technologies. The U.S. has promoted cooperation with allies, such as the U.S.-EU Trade and Technology Council (TTC), the Chip 4 Alliance, and the Quadrilateral Security Dialogue (QUAD), to facilitate technology sharing and export controls, pushing for "decoupling" between the Asia-Pacific region and China. The Russia-Ukraine conflict has further fueled the "new Cold War mentality," with the U.S. leveraging the crisis to rally allies for multilateral export controls and attempting to divide the global economy into two opposing trade blocs.

Western countries have strengthened national security reviews amid geopolitical conflicts, using human rights, Xinjiang-related issues, and broad national security concerns as new tools to institutionalize export controls against China. The EU, the UK, and the U.S. have enacted legislation to upgrade national security reviews, primarily targeting Chinese investments. The U.S. has also exported its pretexts for human rights-based sanctions to allies, leading to a growing confrontation between Western nations and China—another defining feature of the "new CoCom" export controls.

4. Multilateral Export Controls Pose a Direct Threat to China’s High-Tech Industry Development

This section examines the impact of the U.S. revival of the "CoCom Cold War mentality" and its multilateral export controls on Chinese high-tech enterprises. By listing companies like Huawei on restricted entity lists, the U.S. has precisely targeted China’s leading high-tech firms, cutting off access to critical technologies. In 2020, the U.S. made significant revisions to its export control system, expanding military-use restrictions, revoking the "civil end-user license exception" for China, and tightening controls on semiconductor software and technology, effectively preventing Huawei from importing controlled U.S. items directly or indirectly and restricting exports of its products to non-U.S.-affiliated entities. Multilateral containment has placed China’s cutting-edge industries at risk of decoupling, with joint export controls limiting China’s access to advanced technology. The U.S. has repeatedly revised semiconductor export control rules, adding more Chinese entities to restricted lists and blocking China’s access to high-end chips, technology, and manufacturing equipment. It has also pressured allies to expand geographic controls on chip re-exports, severing China’s access to advanced semiconductor products. Under this multipronged containment, foreign capital has retreated, industries have shifted to U.S. allies, China’s high-tech outbound investments have been hindered, and industrial upgrading has faced bottlenecks. The difficulty in obtaining advanced technology has adversely affected corporate innovation capabilities and industrial progress. Multilateral export controls have blocked China from accessing external cutting-edge technology, prevented it from benefiting from global open innovation, and excluded it from high-tech competition. Developed economies have also imposed joint export controls on Xinjiang, with empirical evidence showing that multilateral sanctions reduce regional innovation effects by 15% compared to unilateral sanctions, leading to a noticeable decline in Xinjiang’s invention patent applications.

5. China’s Countermeasures

This section discusses China’s strategies to counter U.S.-led multilateral export controls targeting its high-tech enterprises. These strategies include: advancing market-oriented reforms while adhering to openness and building a dual-circulation development model; leveraging China’s market size advantage, respecting international rules, fostering a fair competitive environment, and deepening cooperation with mainstream nations; balancing technology imports with self-reliance, allowing markets to guide industrial policy; studying U.S. policy tools to refine China’s export control and counter-sanction systems; and urging enterprises to enhance legal risk awareness, ensure compliance, restructure supply chains, and avoid transactions with sanctioned countries and entities. Through these measures, China aims to break through Western high-tech containment and sustain its development achievements.