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Rush Doshi

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@RushDoshi

Asst Professor, Georgetown • Director, CFR China Strategy Initiative • Biden NSC '21-24 • Wrote The Long Game: China's Grand Strategy to Displace American Order
Washington, DC amazon.com/Long-Game-Stra… Joined December 2011
4K Following 40K Followers 9.2K Posts

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Rush Doshi Verified account @RushDoshi
Good time to keep in mind this important research from @SamBresnick and the CSET team.
Sam Bresnick @SamBresnick 10h
1/3 @Nvidia spokespeople are (again!) claiming (falsely!) that its products are not aiding China's military modernization. We @CSETGeorgetown have a bunch of evidence that, in fact, the PLA wants to buy a range of Nvidia chips, including those that are export-controlled.
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Rush Doshi Verified account @RushDoshi
Paul, thanks for the reply here. I often enjoy our exchanges, online and in-person, so please see this in that spirit.

I do think much of what you have written is misleading, incomplete, or in some cases, inaccurate.

To begin, a general point. You dismiss others and appeal to your own authority by stating you are "in the trenches" on this issue. By that, do you mean you're actively helping clients secure licenses from MOFCOM, as you've mentioned elsewhere? If that's the case, I do wonder whether your analysis essentially defending MOFCOM here is at all shaped (even implicitly) by your need for continued MOFCOM access. Doesn't mean you are wrong, but since you're the one who raised the point, it warrants clarification.

On the substance, a few points:

(1) You claim, as always, that the Chinese decision to play the rare earths card wasn't about Trump but was about Biden. But a few replies.

(A) It's true China built the licensing regime over time beginning in 2020 (beginning under Trump), but it's also true they did not pull the trigger until Trump's liberation day tariffs in 2025. In fact, their April actions came two days after those tariffs, and they were in the same package as the 34% retaliatory tariff. This was about tariffs, and later, the affiliates rule.

(B) Under Biden, China never threatened to cut off rare earths to the entire US or global economy. They did so *only* under Trump because he took tariffs to 145% and they were backed into corner. Even now, Beijing officials indicate it was a hard decision they made in the moment. By the way, many admit it was modeled off our sanctions and not export controls because it targeted something so fundamental.

(C) It is true China took some rare earth actions in response to semiconductor controls under Biden. But you know well there is absolutely no comparison between the limited controls they took under Biden and the massive, globally disruptive ones they announced under Trump. The scale of licensing slowdown is wholly different, too.

(2) I suspect the reason you keep saying China's rare earths actions in 2025 were about Biden and not Trump is because you want to undercut the case for US export controls on semiconductors. It seems like motivated reasoning since you and your clients oppose those controls. Separately, your claim that the controls don't work, which was empirically questionable earlier, is particularly thin today, when we've learned that the Chinese government ran an espionage operation against Nvidia's CEO to undercut that same policy.

(3) Your framing treats the PRC's rare earth leverage as a reaction to others. Let's retire this idea. Jessica's piece, in my view and as I've argued elsewhere, is incomplete here. It is true that Beijing didn't plan weaponization in the 1980s and 1990s, but they then did so in the late 2000s ahead of its deployment against Japan. They then used it in 2010 against Japan. They even say so in primary sources. The idea that the formal regime was built beginning in 2020 doesn't detract from the idea they were already applying this tool earlier.

(4) Your oddly spirited defense of China’s non-compliance at Busan rests on two claims: that “we still do not know what China agreed to do,” and that Beijing only had to issue licenses under its own regulations, meaning Busan just required it to hold off on the October controls but allowed it to keep going on the April regime. Both are questionable responses. The basic bargain was clear: China suspended its October controls in exchange for lower US tariffs and suspension of the Affiliates Rule. Interestingly, the US fact sheet also said China agreed to issue general licenses for rare earths and other critical minerals to US end users and their suppliers worldwide, and Beijing didn't deny that. You say the current case-by-case throttling is just fine, but it's contrary to a general license which would mean blanket authorization. Notably, Beijing's actions disconfirm your interpretation. Weeks after Busan, as you well know, MOFCOM began issuing a new category of general licenses to magnet makers, replacing case-by-case approvals. Why create a new licensing channel if the deal only meant returning to the post-April status quo? It's a bizarre reading to say China's April actions were totally off the table: it makes sense only if you now are trying to justify Beijing's non-compliance.

(5) Nor has Beijing delivered on October. MOFCOM’s suspension of its October controls expires November 10. The US says the truce runs to January 10, but Beijing has published no extension to January 10, and we're coming up on the deadline in two days. If China considers itself bound, it should say so in writing, right? The fact it hasn't is interesting.

(6) You bring up military end use, but you know (from your own clients) as well as I do that Beijing isn't just throttling military end users. You then say it's a pipe dream to go back to pre-April 2025. Perhaps, but that isn't really the point. The point is that China isn’t delivering what it agreed to at Busan.

(7) I did say “US companies are not getting licenses.” But if you read the context, you'd know I didn't mean an absolute ban was in place but rather that some companies are struggling to get them, which is why export volumes are down (you and I are in fact cite the same figures here). I think you cherrypicked for a cheap shot reply and didn't look at the whole context.

(8) It is odd that you claim that the US backlog of licenses justifies China violating the Busan agreement. That backlog was not part of Busan. It's quite a reach to justify Beijing's non-fulfillment of Busan by pointing to a third issue that was longstanding.

(9) You disputed my claim that China's Busan non-compliance poses serious risks to the US economy while the US backlog on licenses (which is not relevant for Busan) is not existential for China's economy. You dispute it with two points, both which are dubious.

(A) The first thing you do is say that the licensing backlog may in fact be existential for Chinese companies. You do not prove this, and even if it were true for some companies, the backlog does not directly target a massive segment of the entire economy like manufacturing. Put differently, the United States has no licensing block on something as elemental as rare earths. And as for your points on chips, the United States has in fact licensed billions in chip exports to China. None of this should matter though, because the licensing backlog at Commerce was not part of Busan.

(B) The second claim you make, after saying China faces big threats from our licensing backlog, is to say the US *does not* face a major economic disruption from China's rare earth controls. You argue rare earths access is not a gun to the head of the US economy, and instead of showing why that is true, you simply say it is too complicated to explain and we should take your word for it. This is a bizarre claim: no one else, not Beijing, not Washington, and not industry would agree with you. Moreover, Beijing understands this is serious leverage and that’s why it used it. Just consider that several high-employment manufacturing sectors, autos above all, faced shutdowns last year. You say the US economy is mostly services, so who cares? That's quite an argument! Even a services economy can’t absorb mass plant closures from a shortage of rare earths, and manufacturing isn't a trivial sector (probably at least 10% of GDP). Indeed, the fact this mattered is the very reason there was a Busan deal in the first place.

In sum, I don't find much of what you wrote accurate or compelling. And I do think the proximity to the issue you enjoy, far from being validating, raises questions.

I'll end there.
Paul Triolo Verified account @pstAsiatech 9h
Yes, lets indeed worth correcting the scene here, as this is too important issue in US China relations to be mischaracterized. The perspective here is from someone in the trenches on the issues on a day to day basis, rather than from people who are assessing at a healthy distance, and may not appreciate the nuance of the situation.

First. The Chinese export control licensing regime announced in April 2025 was not a response to the tariffs. As Jessice Chen Weiss and Gloria Xiong lay out brilliantly in the FA piece, the critical minerals controls started in the Biden administration, and really only in earnest in response to the October 2022 US export controls. foreignaffairs.com/china/how-chin…

For people who talk to Chinese officials regularly, the answer was even more clear that the rare earths were a direct, and of course delayed, response to the complexity and sweeping nature of the US controls in 2022, 2023, and 2024. It took MOFCOM and other Chinese ministries time to gain control of a fractious and complex industry of suppliers and traders.

One Chinese official commenting in 2026 noted that China’s addition licensing requirements rolled out in October 2025, were the key piece in “China’s full response to the October 2022 US controls.” So anyone trying to still argue that the Trump tariffs were the cause of Chinese rare earths regime is simply engaging in wishful thinking. The facts on the ground tell another story. In any case, no country could have even an incomplete licensing regime in place after just a few days, so the planning and preparation, including controls on gallium, germanium, graphite, indium, and other critical minerals well predates April 2025.

Second, “China was supposed to let rare earths flow, and they have not” is a fairly wildly inaccurate characterization of the reality on the ground. We still do not know exactly what China agreed to do, there was not statement from the Chinese side specific to rare earth licensing. What we know, again, from first had experience and not unsubstantiated conjecture, is that Beijing agreed to issue licenses, as the US does on controlled items, according to China’s export controls regulations. These regulations state that exports of rare earths and magnets are prohibited for military and defense industrial end use. So, China was not “supposed to” do anything, other than abide by its own regulations. The idea that the situation would go back to what held prior to April 2025 is a pipedream, and the fact that people continue to assert this shows how out of tough with reality they remain.

“US companies are not getting licenses.” This may be the most patently inaccurate of assertions here. Even USTR Greer and Treasury Secretary Bessent acknowledge that roughly 2/3 of licenses are being issued. I know personally of dozens of licenses for critical components and materials issued by MOFCOM just over the past month. MOFCOM has not issued guidance formally extending the suspension of its October 2025 rare earth controls. Until last Thursday, the Commerce Department had not issued a formal Federal Register notice of the extension of its suspension of the Affiliates Rule. Important context.

Third, the reason many people, not just Kyle, in industry rightly raise the issue of the massive backlog of BIS licenses that have not been issued to US companies, is that it seems rather strange to be criticizing MOFCOM for its licensing process, which is just as much, or more complex than that of BIS, and ignoring the licensing process in Washington. Of course these are not part of the formal process, but the are part of what every company impacted by licensing delays experiences, and some US companies are on both ends of these delays. Hence from an industry point of view, the US government should be raising these licensing issues in the context of asking about China’s licensing process. More important context.

Fourth, how does a former US government official know that “the licensing queue…is not existential for Chinese companies? Talk to any of them recently? The licencing queue, coupled with other existing controls, which many believe have produced more damage to US companies than any national security gain, are in fact existential to Chinese companies, and further controls, such as the MATCH Act, are clearly so. But understanding the linkages here is critical, and it is this broader context that matters here.

“But rare earths access is a gun to the head of the entire US economy.” Wow, quite the hyperbole. Understanding how wrong this is would be complex and take some time to explain, and also requires understanding of multiple complex supply chains.

First of all, a licensing regime is just that, a licensing regime. Were the US controls in October 2022 “a gun to the head of the entire Chinese economy?” One could make an argument that they were, even more so than with rare earths and the US economy. China responded with the rare earth controls, suggesting that the US controls were pretty serious.

“The entire economy”” Well, first of all, as noted, the vast majority of licenses are being issued, things are not as easy as they were before the licensing regime, but licenses are being issued, so no, not the “entire economy.” Hint, much of the US economy is services, not advanced manufacturing. What would be more accurate is to say that there are no licenses being given for rare earths and magnets for military and defense industrial end use. Just as the US is controlling semiconductors with potential military end uses. This is what great powers do.

So what does this all mean?

Yes, without real understanding in Washington that Beijing can and will respond to any escalation, and wants to see the Busan truce extended until the end of the Trump administration, we are in a world where the relationship will not be very stable, strategic, let alone constructive. But lets be clear about the causes of the situation, once you start weaponizing supply chains without a clear understanding of the potential consequences, you have to live with the consequences. Here we are.
Note: implementation of the Affiliates Rule and China's October 2025 controls and rare earths and magnets would be catastrophic for global supply chains. Here is the real gun held to the head of the global economy. So why don't both sides rescind the rules completely? That would show real strategic thinking. End Thread.
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Rush Doshi Verified account @RushDoshi
Investigations seem likely, per the next Chair of SFRC.
Senator Chris Coons Verified account @ChrisCoons 13h
The more I learn about the insane relationship between the Trump Administration, Chinese spies, and AI billionaires, the more I’m convinced there is nothing this administration does that isn’t corrupt. Congress will investigate and get answers.
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Rush Doshi Verified account @RushDoshi
More calls for an investigation into possible corruption at the heart of US China and AI policy, this time from @JerusalemDemsas
Jerusalem Verified account @JerusalemDemsas 20h
There is no better avenue for incoming House & Senate Dems to take than hearings on wtf is going on with NVIDIA + Trump corruption + AI policy in the U.S.

It has the virtue of riding the wave of anti-tech populism and directing that energy towards the productive need to stop selling these chips to China.
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