1. Introduction
China's deep integration in global supply chains in the current geopolitical context is leading major economies to take actions to reduce dependence on China as their main source of supply and to diversify. One key area of mounting concerns has been the supply of critical minerals (CMs), especially as governments worldwide are ratcheting up their efforts to transition to a greener economy. For instance, the United States’ (US) Inflation Reduction Act (IRA) of 2022 commits billions of dollars to promote manufacturing, and advancement and deployment of technologies, in clean energy industries.Footnote 1 Equally committed to a green transition, the European Union (EU) has rolled out an expansive tools to enhance its economic sovereignty and global competitiveness in major green technologies, particularly renewable energies and electric vehicle (EV) batteries.Footnote 2
CMs are vital for a range of strategic sectors, including the green industry, which explains why the demand for them is growing exponentially as the green industrial policy proliferates. As the International Energy Agency has estimated, the demand for lithium, nickel and cobalt, and copper and rare earths – key minerals used for the production of EVs and major renewable, such as wind turbines and solar photovoltaics – will increase by 90%, 70%, and 40% respectively over the next two decades.Footnote 3 The extraction of these minerals, however, is concentrated in a few economies such as Latin America and Australia (for lithium), Chile (for copper), Indonesia (for nickel), the Democratic Republic of Congo (for cobalt), and China (for rare earths which include a group of elements vital for clean energy applications).Footnote 4 While China does not control most of the mineral resources, its dominance of the refining operations –intermediate processes necessary for purifying the minerals into usable components for manufacturing – is a major cause of the concern due to China's disruptive potential (as a large share of minerals extracted worldwide are exported to China for processing).Footnote 5 Therefore, based on a shared concern about China as a potential disruptive force in critical supply chains, the G7 governments recently announced a ‘de-risking’ strategy whereby they seek to reduce supply chain dependence on China through individual and joint actions.Footnote 6 Compared to ‘de-coupling’, which would involve completely disengaging with China economically, ‘de-risking’ is seen to be a more moderate strategy aimed at limiting dependence on, and engagement with, China in select strategic sectors while still engaging with China in other economic areas and activities.Footnote 7 Despite the perceived difference in the degree of disengagement, both strategies emerged from the intensified geo-political tensions and strategic rivalry between the US and China such that the US and its allies increasingly treat China as a serious threat to their strategic and economic goals.Footnote 8 Concerns over China's dominance of CMs supply chains, in particular, are worsened by China's increasing recourse to coercive actions and hence the possibility of China weaponizing its dominance of critical supply chains, which was also the G7 Leaders' Communiqué. Thus, where critical sectors are concerned, a ‘de-risking’ strategy may eventually develop into supply chain ‘de-coupling’.Footnote 9 However, a growing body of studies has shown that supply chain ‘de-coupling’ in strategic sectors adversely affects all sectors in individual economies and supply chains worldwide.Footnote 10
Both the US and the EU are developing multi-dimensional strategies to strengthen CMs supply chains, targeting the geographic concentration of extractive and processing activities, particularly the dominant position of China. They seek to foster domestic mining and processing capabilities and partner with allies and like-minded resource-rich economies.Footnote 11 A range of partnerships have been developed through existing trade agreements and new arrangements with an aim to strengthen and expand the friend-shoring of CMs supply chains.Footnote 12 Other resource-seeking economies have followed suit. The United Kingdom (UK),Footnote 13 Japan,Footnote 14 South Korea,Footnote 15 and India,Footnote 16 for example, have each entered a partnership with resource-rich Australia. In doing so, Australia is looking to capitalize on the surging demand for CMs worldwide and attract foreign capital and technological knowhow to help bolster its own extraction and processing capabilities.Footnote 17 At the same time, resource-rich economies, such as Indonesia, Canada, Chile, and Mexico, have taken steps to protect their mineral resources and related industries through export restrictions,Footnote 18 foreign investment screening,Footnote 19 nationalization,Footnote 20 and other defensive tools. These defensive policies, coupled with the potential competition between resource-seeking economies for CM supplies,Footnote 21 could be as disruptive as the feared actions from China. Therefore, they call into question whether de-risking from China is a sensible approach to safeguard CMs supply chains. Already, leading commentators have cautioned that de-risking can only have a limited effect and carries its own risks.Footnote 22
Our key argument in this paper is that the de-risking strategy for securing CMs supply chains is predominantly based on prevailing narratives against China. Yet, a thorough examination of China's CMs strategies and policies is missing in the current academic and policy debate, causing a lack of understanding and potentially irrational policymaking. To fill this glaring gap, we conduct a detailed analysis of the evolution of China's strategies on mineral resources. This analysis offers evidence for an objective assessment of what China's CMs strategies are designed to achieve. We show that these strategies have been primarily aimed at addressing a range of internal challenges and policy priorities in China rather than dominating, weaponizing, or disrupting global supply chains.
In the remainder of this paper, we review the development of China's CMs strategies, starting with Chinese policies and practices to foster the rare earths industry since the 1970s (Section 2). This is followed by a detailed discussion of China's current CMs strategies, released in 2016, focusing on the major inward and outward policy tools employed to pursue the strategies (Section 3). Based on these discussions, Section 4 outlines and reflects on the ‘de-risking’ strategy, including the ongoing development of ally-shoring or friend-shoring CMs supply chains. It argues that the strategy should target risks in supply chains rather than China. To address these risks most effectively, international collaborative frameworks, such as the US-led Indo-Pacific Economic Framework for Prosperity (IPEF), should include, rather than exclude, China in the discussions and cooperation. However, given the current geopolitical context, the World Trade Organization (WTO) remains the only forum that could include the two world's superpowers in cooperative initiatives on global supply chains. Section 5 sets forth some concluding remarks.
2. Developing and Regulating the Rare Earths Industry
China's strategies for CMs date back to at least the 1970s, although for decades they were predominantly focused on the rare earths industry.Footnote 23 The evolution of these strategies was closely aligned with the changing situations of the rare earths industry and the development of national policy priorities. Central to this evolution was a gradual shift from a strong push for the growth of this infant industry at the initial stage to an increasingly balanced approach to address a mix of economic and non-economic goals. Some of the policy tools employed by the Chinese government to support and regulate the rare earths industry continue to form an integral part of China's ongoing strategies on CMs today.
A major policy tool that contributed to the explosive growth of China's rare earths industry in the 1980s was an export rebate system providing a refund of export or value-added taxes up to 17% for rare earth products.Footnote 24 This export promotion strategy was primarily aimed at building the domestic industry by attracting new producers and stimulating production, although it was also used to grow China's foreign exchange reserves.Footnote 25 Coupled with other financial support for the industry, this strategy elevated China to the world's largest rare earths producer and supplier within a short period of time.Footnote 26 However, this strategy also generated a raft of problems, chief among which were illegal mining, over-production, smuggling, depletion of natural resources, and pollution. Since the early 1990s, the Chinese government started to address these problems by limiting domestic production and exports through production quotas, and resource and export taxes.Footnote 27 The government also started to protect rare earths as strategic minerals through restrictions on foreign investment in the upstream activities from exploration to processing of rare earths.Footnote 28 Such foreign investment must take the form of Sino-foreign joint ventures subject to approval by Chinese authorities. Notably, China used the foreign investment policies to facilitate the importation of advanced technology and machinery for the separation and purification of rare earths, which significantly contributed to the development of China's processing capabilities.Footnote 29 In addition, China's robust financial support for the rare earths industry increasingly focused on research and development (R&D) to foster technological capabilities in the processing and commercial application of rare earths.Footnote 30 As it became the world's leader of rare earths processing technologies, China gradually acquired unparalleled scale and efficiency in rare earths processing when compared to its foreign counterparts.Footnote 31 These policies also enabled China to gain a first-mover advantage in, and to become a global hub for, the processing of minerals.
In the 2000s, the Chinese government tightened some of the above-mentioned restrictions, eventually causing rare earth production and exports to fall.Footnote 32 However, illegal mining and smuggling remained rampant due to weak enforcement at local levels, which intensified the concerns about over-exploitation and environmental pollution. To strengthen the regulation of the rare earths industry, the central government released its first Development Plan for the Rare Earths Industry (2009–2015) further controlling exports and mining projects and activities, imposing specific environmental obligations, and systemically restructuring the industry by consolidating rare earth mining operations to a handful of state-owned enterprises (SOEs).Footnote 33 These moves were accompanied by a change of policy priorities to the use of domestic rare earth resources to foster more value-added downstream manufacturing and in a more sustainable manner.Footnote 34 The White Paper on the Situations and Policies of China's Rare Earths Industry, released by the State Council in 2012, set out clearly the aforesaid challenges facing the industry and the government's commitment to strike a balance between supporting the production of rare earths for economic growth and protecting natural resources and the environment.Footnote 35
As the single dominant supplier of rare earths at the time, China's export restrictions caused serious disruptions to global supplies and price hikes and consequently triggered a high-profile dispute launched by the US, the EU, and Japan at the World Trade Organization (WTO) in 2012.Footnote 36 The Chinese measures were widely criticized for effectively ‘subsidizing’ downstream industries (e.g. steel, semiconductors, photovoltaics products) by maintaining low input prices at home to confer a substantial cost advantage to these industries over their foreign competitors.Footnote 37 Nevertheless, the development of the Chinese policies in the rare earths industry reviewed above reveals other strategic goals relating to natural resources preservation and environmental protection through systemic industrial reforms. This was also evidenced by China's timely implementation of the adverse WTO rulings in this dispute. After the WTO tribunals ruled that the measures ran afoul of China's WTO obligations and were not justifiable under the relevant exceptions, China removed the restrictions in a timely manner and, more importantly, used the rulings to push forward the domestic reforms.Footnote 38 As the Ministry of Commerce (MOFCOM) and the Ministry of Industry and Information Technology (MIIT) confirmed in their public announcements, the rulings offered an opportunity for the central authorities to strengthen coordination in an effort to reinforce other WTO-consistent regulatory tools as well as local enforcement of national sustainable development policies in the rare earths industry.Footnote 39
Indeed, the WTO decision stimulated another wave of regulatory actions by the central government including, inter alia, compelling rare earths companies to internalize their environmental costs and combating illegal production through further industrial consolidation.Footnote 40 With the restrictions removed, China's rare earths exports resurged significantly in the following years until 2019 when global demand declined due to the effort of major advanced economies to diversify supply sources and build their own CMs sectors so as to reduce dependency on China.Footnote 41 While China remained a key supplier of rare earths in the global market, its share went below 50% from a peak of 97% before the WTO dispute was initiated.Footnote 42 At the same time, due to China's ambitious and fast-developing industrial policies, including those on green technologies, its demand and imports of rare earths continued to grow.Footnote 43
In 2016, the central government released the second Development Plan for the Rare Earths Industry (2016–2020) which included a comprehensive set of strategies and goals in line with the overarching national plans for the thirteenth five-year period.Footnote 44 To address the longstanding and emerging problems in the industry, the plan emphasized innovation and upgrading, market-oriented growth, consolidation, protection and management of rare earths resources, development of environmental standards, increasing application of rare earths to strategic sectors, and development of new supply chains based on domestic and overseas markets.Footnote 45 Indeed, when it comes to offshore supply chains, China already had years of experience investing in rare earths assets and projects overseas, particularly via SOEs. Some commentators have observed that these investments served to strengthen China's dominance over the rare earths industry.Footnote 46 Increasingly, however, such investments have become necessary for China to secure supplies of rare earths for its own economic needs.
This shift of strategic priorities from ‘dominating’ to ‘securing’ the rare earths supply chains is affirmed in China's current policies for the fourteenth five-year period (2021–2025). For the first time, the central government consolidated its industrial strategies on rare earths into a holistic development plan for the so-called ‘raw materials industry’. This industry, including steel, nonferrous metals, building materials, and new materials sub-sectors, is labelled by the government as ‘the bedrock for the real economy’.Footnote 47 On rare earths, the Development Plan for the Raw Materials Industry, jointly released by three authorities in December 2021, reinforced the strategies and goals from the previous development plan and highlighted the growing challenges for enhancing supply chain security, strengthening and expanding overseas markets, pursuing high-quality development, technological independence, and green and digital transitions, amongst others.Footnote 48 This plan continued to promote industrial consolidation and upgrading to control mining activities and create fewer but more globally competitive national firms.Footnote 49
The above review of the evolution of China's rare earths industrial strategies provides evidence for our observations. It shows that the key driver of these strategies has been China's domestic economic needs and policy priorities. While these strategies did and will continue to have spillover effects on trading partners, such effects were often by-products of China's pursuit of internal regulatory goals. As documented above, China's strategic goals shifted from building an infant rare earths industry by boosting production and exports to promoting the industry's structural and technological upgrade, fostering more value-added downstream sectors, and protecting natural resources, the environment, and security of supply chains. The pursuit of these objectives does not show, explicitly or implicitly, a deliberate strategy of China to cause disruptions in global supply chains or harm to trading partners.
There are numerous examples of economic or trade policies adopted by governments based on their own national interest which inadvertently impacted other nations due to a lack of consideration of the measures’ potential effects in a globalized, interdependent world.Footnote 50 A recent example is the IRA by which the US seeks to reshore EV supply chains via massive subsidies. While the IRA is designed to advance US chosen climate and industrial objectives, it has significant ramifications for trading partners including US allies such as Japan and the EU. As further discussed in Section 4, it also leads to decoupling from China in EV supply chains, including CMs used for EV production. China's policies are similarly designed to advance its own national interest to which the potential global effect of such policies is subordinate in the policymaking. One may argue that even in the extreme case where China imposed export restraints on rare earths to support downstream sectors and address over-exploitation and environmental problems, it was primarily motivated by the need to pursue new economic priorities and tackle longstanding, internal challenges. This observation is supported by recent empirical studies which show that China's export restrictions on rare earths did not target any specific economy.Footnote 51 China's ongoing strategies to secure access to CMs more broadly are substantially similar to those adopted by other major economies. The following section will discuss these strategies in detail to provide more supportive evidence for our assessment of how best to understand their implications for the de-risking approach.
3. Critical Minerals, Economic Security and Supply Chains
China is not only a predominant supplier of CMs but also one of the world's top importers of many of these minerals which are needed to support the industrial policies that have underpinned its decades of economic growth.Footnote 52 As climate policies become central to its ‘development vision and strategy’, China has become increasingly ambitious in its climate actions.Footnote 53 Thanks to a vast array of supportive policies, renewable energy and EV sectors – the two pillars for a low-carbon energy transition – have undergone tremendous development over the past decade. China now leads the expansion of renewable energies, EVs, and related technologies globally.Footnote 54 At the same time, these green technologies are also key components of China's technology- and innovation-oriented development plans and remain the country's prioritized, strategic high-tech sectors.Footnote 55 This entrenched commitment to an intertwined green and technological transition has been a major driving force behind China's growing demand for CMs. Thus, like other resource-seeking economies, China also faces considerable challenges associated with supply shortages and price volatility and has been developing strategies to strengthen its supply chains.Footnote 56
3.1 Overarching Strategies
China did not have an official list of CMs in its national policy until recently. The National Plan for Mineral Resources (2016–2020) (hereinafter ‘Mineral Resources Plan’ or ‘Plan’), for the first time, created a pool of 24 ‘strategic minerals’, including six energy resources, 14 metallic minerals, and four non-metallic minerals – see Table 1.Footnote 57 The Plan outlines the missions and targets for that five-year period and longer-term goals up to 2025.
Table 1. China's national list of critical minerals
The strategic minerals are considered indispensable for the protection of China's national and economic security and for the growth of its strategic, emerging industries. Notably, the minerals essential for major green technologies, such as lithium, copper, nickel, cobalt, graphite, zinc, chromium, and rare earths, are all included in the list. This is a testament to China's determination to promote its green industries particularly the EV and renewable energy sectors. Meanwhile, this list also reflects China's concerns about potential shortages and supply chain risks due to fast-growing domestic demand and intensified global competition.Footnote 58 As estimated, there will be a steady and significant increase in China's domestic need for a wide range of minerals until 2035 or beyond.Footnote 59 While foreign observers have reported that China remains a major supplier of certain CMs,Footnote 60 Chinese scholars have cautioned that China does, or will in the future, face shortage and supply problems in relation to at least nine minerals, including cobalt, lithium, chromium, nickel, beryllium, zirconium, manganese, niobium, and tantalum.Footnote 61 Thus, leading commentators in China have categorized these and some other minerals as ‘shortage strategic and critical minerals’ and suggested that the national list be updated accordingly.Footnote 62
The Plan outlines China's overarching strategies for the entire mineral resources industry, combining inward and outward ones. The inward strategies focus on fostering mining activities, improving efficient use and preservation of minerals, upgrading industrial structures, advancing innovation, and promoting a circular economy and ‘green development’ of the industry. The Plan treats the inward strategies as being fundamental to China's minerals security and directs the provision of fiscal support and other differential and preferential treatment to the strategic minerals segment. It also mandates the establishment of risk warning and reporting mechanisms to provide the information for the central government to develop policies and capabilities to guide the development of the strategic minerals sector and protect the security of these resources.
The outward strategies focus on promoting international cooperation on mining activities in China and globally. On the one hand, the Plan commits to enhancing the access for foreign investors to China's mining industry with an aim to attract foreign capital, advanced technology, and managerial skills and expertise. On the other hand, the Plan emphasizes collaboration with economies involved in the Belt and Road Initiative (BRI). Such collaboration targets not only mining activities but also joint forums and platforms for policy and information exchange as well as R&D and training of executives and specialists. The Plan also calls upon the creation of large and globally competitive Chinese multinational companies to strengthen and expand mining projects overseas, using China's existing and future joint projects within BRI economies (such as infrastructure) as a pathway. This strategy based on outbound investment and regional and global cooperation is essential for China to compete with other resource-seeking economies, stabilize CMs supply chains, and overcome escalating geopolitical tensions and uncertainties more broadly.
In the current fourteenth five-year period (2021–2025), the central government has not published an updated strategy document yet. Nevertheless, the Fourteenth Five-Year Plan, China's top-level national blueprint, places growing emphasis on the green transition as a core element of China's pursuit of high-quality, sustainable development.Footnote 63 The plan also carries on China's robust industry policy with even stronger commitments to promoting the development of strategic, emerging industries, including the major green sectors noted above. Internally, the plan reiterates the need to safeguard domestic supply chains in general and, more specifically, the security of CMs by strengthening state control of these minerals, improving the safety of reserve mechanisms, and accelerating exploration activities. Externally, it encourages cooperation on global supply chains, standards setting, trade and investment liberalization, and facilitation etc. through existing and new trade agreements and the BRI. Accordingly, the Fourteenth Five-Year Plan reaffirms the missions and goals envisaged in the Mineral Resources Plan.
Following these two national plans, local governments have issued their own plans for mineral resources at the provincial level for the fourteenth five-year period, including longer-term goals up to 2035.Footnote 64 Based on local endowments and advantages, the provincial plans focus on similar or different groups of (critical) minerals and set specific exploration plans and mining targets. At the same time, they all emphasize the balancing act towards environmental protection and sustainability by developing and applying advanced technologies, planning and management systems etc. at different stages of mining activities.
3.2 Policy Tools for the Inward Strategies
3.2.1 Subsidies
Subsidies are a longstanding internal policy tool employed by the Chinese government to boost domestic mineral exploration and production. In the past few years, the use of subsidies has increasingly focused on the exploration of CMs. Between 2017 and 2021, central and local governments provided fiscal support for exploration activities on a yearly basis leading to the injection of billions of government funding in these activities.Footnote 65 In a recent announcement, the Ministry of Natural Resources reaffirmed that the exploration of CMs is crucial for the stable supply and reservation of these minerals and hence will remain the priority of the government's fiscal support.Footnote 66 Since 2021, local governments have committed to spending more on the exploration of CMs available in their regions for the green transition.Footnote 67
Apart from direct transfers of funds, preferential taxation and loans are the other two major types of subsidy programs in the mining industry. The Natural Resource Taxation Law authorizes local governments to provide tax exemptions or reductions for the exploration of a wide range of minerals.Footnote 68 When it comes to metallic CMs, such as copper, nickel, cobalt, lithium and zirconium, the General Guidelines for Non-ferrous Metals Industry, released by the State Council in 2016, commits to increase tax benefits and policy loans for mining companies particularly actions taken to advance the technological upgrade and digital and green transitions of the mining industry.Footnote 69 Local governments have rolled out more specific subsidy programs. For example, in 2020 the Yunnan government provided 1 billion yuan and covered up to 80% of interest costs for entities engaging in the production and reservation of tin, germanium, indium, copper, electrolytic aluminum, lead, and zinc.Footnote 70 The government of Shangrao City provided not only direct transfers of fund, tax refund, and policy loans but also input for its local non-ferrous metals sector, including electricity and gas, at discount rates.Footnote 71 It also scaled up fiscal support to build a supply chain management platform for supply chain integration across upstream and downstream sectors.
Apart from exploration activities, Chinese subsidies in the mining sector have continued to focus on R&D to advance new mining and processing technologies particularly those needed for the green development of the industry.Footnote 72 Accordingly, China has applied the same strategy and policy in the rare earths industry to maximize its global competitiveness in the processing of other CMs, such as lithium, nickel, and cobalt.Footnote 73
3.2.2 Licensing
The massive support for mining activities is balanced by policy tools aimed at enhancing the sustainability of the mining industry and the protection of the environment. The first major tool is a nationwide approval system for all mining activities introduced in 1986.Footnote 74 This system is essential for the central government to plan exploration activities at the national level and control the allocation of mining rights to qualified entities that are mainly state-owned. As noted in Section 2, this system was used to regulate and restructure the rare earths industry to address problems of illegal mining, smuggling, and pollution. Restrictions on the granting of mining rights in the rare earths industry as well as mining quotas have remained in place even after the Mineral Resources Plan was introduced in 2016 to promote the exploration of CMs.Footnote 75 While similar restrictions have not been applied to other CMs essential for the green transition, in practice the mining and production of these minerals is similarly concentrated in the hands of a few SOEs.Footnote 76 Nevertheless, the lack of restrictions on the production of these CMs is indicative of China's growing demand for these minerals. This is evidenced by the reports of the China Geological Survey which assess the global and domestic reserves of select CMs. Its latest report released in July 2023 found that a list of nine CMs – iron, chromium, nickel, cobalt, lithium, copper, aluminum, phosphorous, and potassium – is at higher supply risk compared to other minerals.Footnote 77 This list is still being developed as the authority continues to monitor domestic and global reserves of CMs. As the exploration of CMs remains a policy priority, the tension between mining activities and environmental protection is destined to intensify in the foreseeable future.
3.2.3 Environmental Protection and Circular Economy
To deal with the challenges associated with its environmental goals, the Chinese government has consistently stressed the need to strike a balance between CMs security and sustainable development. Thus, the green development of mining activities has become a central element of China's inward strategies on CMs. Apart from the licensing system, which contributes to managing and standardizing mining activities, the government has introduced a series of laws and regulations to mitigate the adverse effects of mining on the environment. Like the measures applied to the rare earths industry outlined in Section 2, these policy instruments are designed to ensure mining activities are increasingly aligned with national environmental goals. Thus, they require mining entities to comply with licensing conditions and environmental standards and obligations and to internalize environmental costs while imposing severe penalties on those that fail to do so.Footnote 78
The other major set of policy tools focus on promoting a circular economy. As early as in 2005, the National Development and Reform Commission (NDRC) issued a policy document requiring the maximization of the recycling and utilization of wastewater, exhaust gas, and waste residue generated during mining and smelting.Footnote 79 Commentators also put forward a 3R strategy to build a ‘mining circular economy’ through reducing the consumption of mineral resources during exploration, processing, and utilization, reusing waste from these activities, and recycling used resources.Footnote 80 This strategy is incorporated into the Circular Economy Promotion Law (as amended in 2018),Footnote 81 which promotes a circular economy nationwide. As regards mining activities, the law requires the competent authority to assess whether the mining techniques used by entities would achieve the relevant standards and enhance efficient use of resources, mining quality, reuse of mine wastewater, recycling of resources etc. Similar requirements can also be found in other laws that regulate specific segments of the circular economy.Footnote 82 More recently, the Implementation Plan for Carbon Peak in the Non-ferrous Metals Industry, published by the NDRC in November 2022, set a specific recycling target whereby the proportion of ‘recycled metal supply’ must reach over 24% during the fourteenth five-year period as well as a longer-term goal to develop a green, low-carbon circular industrial system by the end of the fifteenth five-year period (i.e. 2026–2030).Footnote 83 It is therefore undeniable that the sustainable development of the mining industry plays an indispensable role in China's overall strategies on CMs, although the balancing act required to achieve such sustainability will remain an existential challenge for Chinese leaders.
3.2.4 Risk Warning and Reporting Mechanisms
The final major policy tool we briefly review in this paper is risk warning and reporting mechanisms. Introduced by the Mineral Resources Plan in 2016, such mechanisms are designed to collect the information necessary for the government to monitor the supply and demand of CMs as well as to formulate timely policy responses to potential shortages and uncertainties. Commentators have observed that such mechanisms can play a critical role in helping the Chinese government develop better plans for mining activities and sustainable development as well as to secure a stable supply of CMs at reasonable prices in the context of growing international competition for these minerals.Footnote 84 As noted above, the China Geological Survey has embarked on some pilot work on this front via its periodic reports on domestic and global reserves of CMs. The authority is progressively expanding the list of CMs for assessments and going forward is committed to updating the relevant data more frequently.Footnote 85 At the same time, local governments are developing mechanisms for monitoring and reporting CMs security risks within their regions.Footnote 86
The policy and regulatory developments reviewed above are not exhaustive. Nevertheless, they are the major components of China's CMs strategies and hence evidence of China's priorities and future plans in this space. Through the inward strategies, China is clearly focused on addressing the mounting challenges it faces to secure CMs supplies while ensuring sustainable development. Given the pressing need to uplift the technological and green capabilities of its mining industry and to secure CMs supplies from both domestic and foreign sources, China has sought to complement the inward-looking strategies with outward-looking ones.
3.3 Policy Tools for the Outward Strategies
3.3.1 Inbound Foreign Investment
China's longstanding practices in using foreign investment to support its own industrial policies and economic priorities are widely documented.Footnote 87 While the mining industry has been one of the most protected sectors, it is being slowly opened up for foreign investment. The balancing act here is the desire for advanced foreign technology and expertise on the one hand and the need to limit the participation of foreign equity in mining on the other hand. Thus, the Mineral Resources Plan sets forth an overarching principle to promote foreign investment in the mining sector with a focus on mining technologies, equipment, and managerial skills for exploration, efficient utilization, recycling, environmental management, and ecological restoration.
When the ‘negative list’ approach was introduced under China's new Foreign Investment Law in 2019,Footnote 88 foreign investors were only prohibited from investing in rare earths, radioactive minerals, such as uranium, and the exploration and mining of tungsten.Footnote 89 These limited prohibitions remained unchanged in the following two years.Footnote 90 In 2022, all prohibitions were lifted and replaced by a general permission for foreign entities to invest in the mining sector subject to the approval of competent authorities depending on the projects or activities involved.Footnote 91 Exploration, mining, transfer of mining license etc. require prior approval of the Ministry of Natural Resources or its departments at the provincial or equivalent level.Footnote 92 At the same time, the Chinese government also maintains a separate ‘positive list’ of industries in which foreign investment is encouraged. The currently applicable list released in October 2022 includes the exploration and mining of minerals in short supply, new technologies that improve the utilization of mineral residue, and mine restoration, amongst others.Footnote 93
This gradual opening-up of the mining industry for foreign investment is a strategic move to facilitate the entry of foreign capital, technology, and expertise in line with China's policy priorities for the development and modernization of the industry. Meanwhile, the approval and licensing system has offered a safeguard mechanism allowing the Chinese government to maintain control over mining resources and activities. Thus, despite the gradual opening-up, foreign investment in the mining sector has remained strikingly minimal in terms of both the number of investors and the value of investment since 2019.Footnote 94 Besides, China's security laws highlight the security risks that may arise from foreign investment in critical energy and resources and require such investments to apply for security review.Footnote 95 This review provides another layer of control by the Chinese government over mining resources and activities. Going forward, however, China will need to ensure that these ‘screening’ mechanisms are not used in ways that may disincentivize foreign investment. To achieve its CMs industrial strategies, China will need to create a more open, transparent, and predictable regulatory environment for foreign investors.
3.3.2 Outbound Direct Investment and the Belt & Road Initiative
Outbound direct investment is another longstanding, major policy tool used by the Chinese government to gain access to mineral resources overseas. When the well-known ‘Go Global’ policy was introduced in China's Tenth Five-Year Plan in 2000, energy and resources were already one of the prioritized sectors.Footnote 96 The government provided significant financial support and preferential policies to promote overseas exploration projects targeting minerals in short supply and in urgent need for economic development in China.Footnote 97
While such investment is dominated by SOEs, major private enterprises have also invested abroad in resource extraction. Both SOEs and private entities are encouraged by government policies that provide financial support and impose less stringent requirements on outward investment in the mining sector as compared to others.Footnote 98 The financial support in particular gave advantage to Chinese mining entities in the long haul as they were able to invest in exploration and extraction of minerals which were not yet economically viable, such as those for the green transition, well before their competitors. Similarly, it has enabled these entities to operate in politically riskier jurisdictions such as central Africa which Western investors usually shy away from.Footnote 99 Additionally, China has been encouraging its domestic industries to invest in the extraction of the minerals they need abroad so as to vertically integrate. The goal of such a strategy is to avoid price volatility in commodity markets as the minerals are sold at stable intra-group price and to ensure security of supply in case of shortages as companies can reserve internal production of minerals for downstream processing in China. This strategy has notably been followed by Chinese steel makers which own large deposits abroadFootnote 100 and, more recently, by Chinese EV makers, some of which are fully vertically integrated from mineral extraction to EV assembly.Footnote 101
In short, the ‘Go Global’ policy and the associated supportive programs led to explosive growth of Chinese outbound investment particularly in the energy and resources sector.Footnote 102 Today, Chinese investment in resource-rich countries, such as Australia, Chile, Peru, Indonesia, and the Democratic Republic of Congo, remains predominantly focused on mining projects.Footnote 103
To enhance market access for its investors in resource-rich economies, China has resorted to two major tools: free trade agreements (FTAs) and the BRI. China has an existing FTA with Australia, Chile, and Peru.Footnote 104 While China does not have an FTA with Indonesia on a bilateral basis, both countries are parties to the China–ASEAN FTA and the Regional Comprehensive Economic Partnership (RCEP).Footnote 105 However, China's accomplishments in securing market access commitments under these FTAs have been limited, although the established partnerships provide a good foundation for further development of these commitments. For example, in the FTA negotiations with Australia, one of China's primary goals was to relax Australia's foreign investment review processes. While China was successful in seeking more favorable treatment for its private investors, all investments by Chinese SOEs in Australia are still subject to review.Footnote 106 Since SOEs dominate China's investment in mining projects, Australia's screening mechanism remains a major hurdle to such investments. More recently, Australia introduced a stand-alone national security review mechanism which effectively renders all foreign investment in mining projects reviewable.Footnote 107 Increasingly, Australia has used its screening mechanisms to block Chinese investments, particularly those by Chinese SOEs.Footnote 108
Under the investment chapter of the China–Peru FTA, both parties commit to promote and protect bilateral investment via standard obligations, such as non-discrimination, fair and equitable treatment, full protection, restrictions on expropriation and nationalization, and transfer of investment returns.Footnote 109 This FTA also allows investor-state disputes to be resolved via bilateral negotiation or international conciliation or arbitration, thereby creating mechanisms to enforce the obligations. As far as the mining industry is concerned, Peru maintains a general carve-out which precludes foreigners from acquiring ownership in any mine within fifty kilometers of the Peruvian border.Footnote 110 This is the only major differential treatment applicable to all foreign investors vis-à-vis domestic ones,Footnote 111 meaning that the FTA does not confer more favorable treatment on Chinese investors.
Under the China–Chile FTA, Chile retains the freedom to regulate and screen foreign investment and does not provide more favourable treatment for Chinese investors either.Footnote 112 However, this FTA contains ‘reasonable endeavour’ clauses to facilitate cooperation on mining projects.Footnote 113 Such cooperation has been promoted via bilateral Strategic Dialogue on Economic Cooperation and Coordination, which currently focuses on the development of copper smelting technology, lithium resources, clean energy, among other areas.Footnote 114
The investment chapter under the China–ASEAN FTA has provisions on investment liberalization and protection and enforcement similar to those of the China–Peru FTA.Footnote 115 It also has a general provision that encourages the parties to cooperate in a range of areas including mining.Footnote 116 RCEP's investment chapter provides a higher level of liberalization by including a general prohibition on a range of performance requirements relating to, for instance, imports and exports, use of local content, sale restrictions, and technology transfer.Footnote 117 The chapter also includes investment facilitation commitments which require the parties to streamline domestic screening processes and promote transparency and policy exchange.Footnote 118 These additional commitments are in line with recent developments in international investment facilitation rulesFootnote 119 and would contribute to enhancing the market access of Chinese investors in RCEP economies, including resource-rich Indonesia.Footnote 120
Overall, China's strategy to promote investment in mineral resources overseas has relied more on a ‘soft law’ approach via cooperation while pursuing binding obligations only incrementally. This approach leaves room for both China and its trading partners to maintain their existing and preferred regulatory regime in the mining sector. This approach is also manifested by China's effort to strengthen diplomatic relations and expand cooperation with economies associated with the BRI. By June 2023, China had signed a memorandum of understanding (MOU) with 152 economies.Footnote 121 While the MOU develops a primary framework for general or sectoral cooperation, China and its counterparts have also signed numerous secondary agreements which implement the primary agreements and set forth the details of cooperation in individual projects.Footnote 122 Most of these agreements are not publicly available. However, the combined effect of these agreements has been the explosion of Chinese investment in BRI-participating economies particularly in infrastructure projects tailored to the need of the host countries.Footnote 123 These projects have facilitated cooperation in other projects including mining, creating a win-win situation for the economic growth of the host countries on the one hand and China's demand for energy and resources on the other hand.Footnote 124 As estimated, Chinese companies hold an interest in around 11% of global cobalt and copper production, 13% of global lithium production, 6% of global nickel production, and 63% of global rare earths production.Footnote 125 Yet, it is also important to recognize that except for rare earths, China does not hold a dominant position in global production of major CMs which is controlled by companies of other major players, such as the UK, the US, South Africa, Russia, and Canada.Footnote 126 To reinforce its supply chain security in the global race for CMs, China has been ratcheting up its effort to expand investment in resource-rich countries, particularly its existing trading/BRI partners.Footnote 127 However, resource-rich economies’ growing protection of their mining resources due to security and other economic development concerns, as noted earlier, is posing mounting challenges for China's pursuit of its strategic goals.Footnote 128
Finally, it is worth noting that China has taken a different, more collaborative stance than that of the EU and the US when dealing with resource-rich developing countries' desire to use their own CMs to move up the industrial value chain. For example, China has worked with Indonesia to develop downstream nickel ore industries. Indonesia has some of the world's largest reserves of this mineral but used to export most of it to China for processing. To develop downstream industries, such as stainless steel or EV batteries, Indonesia started to impose export restrictions on nickel around a decade ago. While the EU challenged Indonesia's action at the WTOFootnote 129 and imposed trade defence duties on imports of downstream products exported from Indonesia,Footnote 130 China, instead, signed a number of BRI agreements with Indonesia to encourage Chinese companies to invest in Indonesia's mining and downstream industries and promised preferential finance for these ventures.Footnote 131 This cooperative approach has worked well for China to develop further investment opportunities as a trusted partner in resource-rich developing countries.
3.3.3 Trade and FTAs
For China's exploration and mining activities overseas to satisfy its domestic demand for CMs, Chinese investors must be able to sell the mining outputs back home. Thus, China has maintained low to zero import tariffs on energy and mineral resources, including major green minerals: see Table 2.Footnote 132 Partnerships established with BRI economies may have also helped facilitate exports of goods including minerals to China.Footnote 133 Moreover, China has sought to include a general prohibition on export restrictions in its FTAs even though such clauses merely incorporate the relevant WTO rules (i.e. GATT Article XI:1).Footnote 134 Like the general WTO rules, these FTAs also leave export duties unregulated. Going forward, it would be in China's interest to include restrictions on export duties in its FTAs because it has already agreed to eliminate such duties, except for a short list of exemptions, under its WTO accession package.Footnote 135 However, given the rise of export restrictions on CMs in resource-rich developing economies, the efficacy of trade rules would increasingly hinge on how to ensure they could be effectively enforced and how to dissuade the abuse of such restrictions.
Table 2. China's import tariff rates for green minerals in 2023Footnote 136
As shown in Section 2, China itself resorted to export restrictions and taxes on CMs in breach of its WTO obligations. Although the WTO dispute settlement system was effective at pushing China to comply with its obligations in China–Raw Materials and China–Rare Earths,Footnote 137 it cannot eliminate the possibility that these measures may be reintroduced. After the disputes, China did reimpose similar export restraints on 11 raw materials in 2016.Footnote 138 However, the US and the EU were again able to use the system to push China to remove these measures in a timely fashion,Footnote 139 which testifies to the effectiveness of the system when dealing with China. Since then, China has maintained an export tax on a list of raw materials, including two green CMs (i.e. nickel and chromium),Footnote 140 largely consistently with the exemptions envisaged in its WTO accession commitments.Footnote 141 China has also applied an export licensing system on some CMs, including nickel, cobalt, chromium, zirconium, and rare earths,Footnote 142 although it does not seem to have maintained restrictions (e.g. quotas) on their exportation. Nevertheless, China may well reintroduce export quotas on CMs when needed. There are at least three situations in which China may do so.
First and foremost, export restrictions may be reinstated when they are needed to address the internal challenges China faces in pursuing a delicate balance between securing domestic supply and reservation of CMs for economic development and advancing its climate and sustainability agenda. In these circumstances, China will likely prioritize domestic policy needs over international obligations, at least on a temporary basis.
The second situation is where retaliation becomes a desirable policy response to actions by other states. As discussed in detail elsewhere, China has pursued a defensive strategy in response to US sanctions since the outset of the bilateral trade war in 2018.Footnote 143 Faced with US bans on the sale of high-tech microchips to China, China recently curbed the exportation of gallium and germanium (two niche minerals used to manufacture electronics and semiconductors), although the Chinese action was arguably not intended to cause immediate, major economic impactsFootnote 144 but to demonstrate its will and ability to take more meaningful retaliatory actions if the US sanctions continued to escalate. China categorized the two minerals as dual-use items under its Export Control Law 2020 and sought to justify the export restraints on the ground of national security.Footnote 145
The third situation concerns the possibility that China may resort to more assertive foreign policies and proactive/coercive actions in dealing with sensitive political matters. However, the circumstances in which China may take such actions are arguably limited. China's coercive actions in recent times suggest that the triggering events need to be perceived by Chinese leaders as causing or having the potential to cause political instability in China. The most cited examples involve human rights issues in Xinjiang, diplomacy in Hong Kong and Taiwan,Footnote 146 which are matters of the highest sensitivity in China's political system. To protect its own credibility in the global economy, it is likely that China would strictly confine any coercive actions to such highly political sensitive circumstances. This means that China would not weaponize trade and disrupt supply chains as often and widely as is sometimes perceived. Rather, it is reasonable to observe that China will seriously weigh the benefits and costs of economic coercion and become increasingly cautious so as to minimize the negative impact on its global reputation and engagement.
This detailed analysis of China's strategies on CMs has reinforced our observation that these strategies are not designed or intended to cause disruptions in global supply chains. China has consistently prioritized its domestic policy goals seeking to find solutions to its internal challenges. While these strategies are adopted to enhance China's global competitiveness and supply chain security rather than pursue confrontation, they have important economic and strategic implications for China's trading partners. Apart from the external tools on trade and investment which directly impact or compete with other economies in CM supply chains, internal tools for environmental, developmental, and other legitimate goals would also affect trading partners indirectly. For instance, the consolidation of SOEs in the mining industry to better manage and standardize mining activities for sustainability significantly elevates the global competitiveness of these entities in CM supply chains in terms of bidding for mining projects overseas, pricing power, production efficiency, etc.Footnote 147 SOEs may also be used as a vehicle to pursue strategic goals such as controlling CM assets, processing facilities, supplies or exports, as demonstrated by China's outbound investment policies and defensive or proactive actions in response to policies adopted by other governments. Overall, China's CM strategies have enabled it to gain a first-mover advantage in global mining activities and a more advanced position in securing supply chains. Like similar policies developed in other economies, these strategies and policies tend to complicate and affect CM supply chains, even just as a side effect. However, given the fast development of similar CMs strategies in other major economies, it would be unwise to argue that China should not develop its own. The sensible solution to the potential disruption or confrontation in CM supply chains is international cooperation, which is discussed below.
4. Rationalizing the De-Risking Strategy
The term ‘de-risking’ was undefined in the G7 Leaders' Communiqué of 20 May 2023 and remains ambiguous today. When it comes to China and CMs, the Communiqué essentially raised the following concerns: over-reliance on China for the supply of CMs which can be affected by China's non-market policies and practices and economic coercion.Footnote 148 In a policy brief released on 30 June 2023, the EU reiterated the necessity to pursue constructive and stable relations with China while at the same time reducing critical dependencies and vulnerabilities, including in its supply chains, and de-risking and diversifying where necessary and appropriate.Footnote 149 In an effort to align its approaches to China with those at the EU level, Germany released a detailed China Strategy in July 2023. This Strategy considers China as a serious competitor and systemic rival and calls upon ‘reducing dependencies in critical areas, keeping geopolitical aspects in mind when taking economic decisions, and increasing our resilience’.Footnote 150 However, none of these documents flesh out the meaning of ‘de-risking’.
The ambiguity left in the de-risking strategy provides the political flexibility for the US and the EU to adjust their approaches to China in light of changing circumstances. The strategy's practical scope can, therefore, vary depending on how it is implemented. Through economic sanctions exemplified by bans on chips exports and investment in select high-tech sectors, the US's de-risking has in effect embraced the abandoned de-coupling strategy.Footnote 151 It is not impossible that the EU's de-risking may also entail de facto de-coupling in critical areas.
As far as CMs are concerned, there is already a clear trend of ally-shoring leading to the fast development of a range of partnerships aimed at moving CMs supply chains away from China and Chinese entities and breaking up China's dominance over processing of CMs.Footnote 152 These partnerships are largely based on aspirational terms seeking to foster cooperation among like-minded economies on diversification of supply chains, investment in and development of upstream and downstream sectors, R&D, standards setting, regulatory transparency and information exchange, etc.Footnote 153 The Supply Chains Agreement under the IPEF, released on 7 September 2023, was a significant expansion of the ally-shoring of supply chains to a much broader context with China excluded. This agreement seeks to consolidate and institutionalize supply chain initiatives by creating the relevant bodies to facilitate and oversee the development of specific action plans as well as a Supply Chain Crisis Response Network to ensure emergency communications.Footnote 154 Major areas of cooperation include:
• detecting (potential) supply chain risks, disruptions, and bottlenecks,
• mobilizing investment,
• promoting regulatory transparency,
• enhancing technical assistance and capacity building,
• minimizing market distortions and unnecessary trade restrictions, and
• promoting labor standards.
The emerging partnerships on CMs supply chains have thus become an integral element of the de-risking strategy. Led by the US, these partnerships are arguably driven primarily by the ongoing geopolitical tensions with China rather than the best approaches to addressing challenges for (CMs) supply chains. This might be similar in the case of the growing number of CMs strategic partnerships signed by the EU with its trading partners such as Kazakhstan, Ukraine, and Namibia.Footnote 155 Indeed, one of the goals of such partnerships is to increase financing not only for mining projects in these countries but also for processing. This serves the dual goal for the EU to sell the partnerships as win-win for its partners by helping them to move further up in the value chain as well as move some CM processing away from China.
These external partnerships are complemented by domestic actions. As flagged above, through tax credits to EVs made of inputs originating in the US or its preferential trading partners, the US's IRA seeks to push EV makers, even outside China, to not rely on Chinese CMs, thereby effectively decoupling from China in CM supply chains. To include allies originally ineligible for the IRA subsidies, the US and Japan entered an Agreement on Strengthening Critical Minerals Supply Chains.Footnote 156 The US is also negotiating similar arrangements with other allies including the EU.Footnote 157 At the same time, under its proposed Critical Raw Materials Act, the EU is suggesting to develop new tools to ensure that the EU does not rely on a single source of CMs supply for more than 65% of its needs of a given mineral.Footnote 158 Here, it is notable that the US's actions take a much harder stance towards China as the EU does not aim to cut all ties.
For economic, strategic and security reasons, it is rational for governments to diversify supply chains, avoid over-dependency on any single source of supply and compete in resource-abundant markets. China has pursued such diversification and global competition via its CMs strategies discussed in this paper. Major resource-seeking economies, including the US and the EU, have also adopted similar industrial policies and strategies to secure access to CMs in support of a green transition.Footnote 159 These strategies will not only intensify competition among themselves but also impact or disrupt global supply chains in similar ways as China's strategies. The same can be said about the defensive policy tools adopted by resource-rich developing economies such as nationalization, local content, or performance requirements and export restrictions.
Excluding China from discussions and cooperation on global supply chain matters turns ‘de-risking’ into de facto ‘de-coupling’, which is infeasible and tends to increase rather than reduce disruptions. It is unachievable because China remains a central player in global supply chains including CMs and a top trading partner with a majority of the world.Footnote 160 It is also because apart from the US, other economies, including major US allies, continue to work with China under BRI, FTAs, and other existing and potential initiatives. It generates disruptions because de facto de-coupling is likely to cause escalation of geopolitical tensions and retaliatory actions, consequently creating unnecessary trade fragmentation, barriers, and uncertainties which undermine supply chain resilience.Footnote 161
The de-risking strategy should focus on addressing the supply chain risks rather than targeting China. As discussed in this paper, China's CMs strategies, although proactive and ambitious, are primarily aimed at strengthening its strategic competitiveness for economic development and security. This distinction between competition and confrontation is crucial for rationalizing supply chain strategies going forward. Instead of confrontation, the de-risking strategy should focus on promoting fair competition and cooperation. In almost all aspects of the IPEF Supply Chains Agreement, the governments involved would be better off to include China in the deliberation and cooperation. The IPEF's collective responses to supply chain risks and emergencies can be more effective with China's participation. It would also provide an alternative framework, apart from the WTO, to push China to increase regulatory transparency and coordination while disincentivizing it from non-market policies and practices as well as coercive actions. Finally, it would also provide an opportunity for collective mining-related standard-setting on environmental, labor, and other issues.
However, given the current geopolitical context, it would be unrealistic to expect that the IPEF would be open to China. Thus, the WTO remains the only forum that would include both the US and China in the deliberation and cooperation on global supply chain issues including CMs. Given the global nature of these issues, it would also be ideal if the matters contemplated in the IPEF Supply Chains Agreement can be discussed at the multilateral level. With the world's two superpowers involved, this would enhance certainties in the global economy as to how they may manage their tensions, respond to existential challenges including supply chains and economic security, and hopefully play a leadership role in stabilizing and advancing the rules-based economic order.
5. Conclusion
The proliferation of green industrial policies worldwide is leading to a global race for CMs based on a wide array of strategies and policy tools to secure CMs supply chains. While resource-rich developing economies have relied predominantly on defensive policies to protect their mineral resources and foster industrial capabilities in related sectors, the US and its allies have been developing networks for ally-shoring CMs supply chains while de-risking from China. Leaving the de-risking strategy undefined, they maintain the political flexibility to pursue de facto ‘de-coupling’ when needed. The US's bans on exports of chips to and investment in select high-tech sectors in China are telling examples of de-coupling. As the geopolitical tensions and strategic competition between the world's two superpowers intensify, the change of the policy description from de-coupling to de-risking may not change the substance in practice. In any case, treating China as the ‘risk’ will remain indispensable for the political demand in the US for the foreseeable future.
Other countries should react rationally to extreme policies adopted amid geopolitical tensions. US allies have already started doing so, causing the strategic reorientation from de-coupling to de-risking, although they still view China as a major risk in global supply chains. Unlike the US, even the EU is not aiming at cutting all ties with China when it comes to CMs. Other economies such as many IPEF members have continued or even broadened engagement with China in economic activities. De-coupling or its variations are therefore infeasible and would cause disruptions in global supply chains.
The de-risking strategy should focus on addressing supply chain risks rather than targeting China. Rationalizing the strategy in this direction, as we have argued in this paper, must be based on a comprehensive understanding of China's strategies. Through a detailed analysis of China's strategies on CMs, we have shown that these strategies have been used to tackle the existing and emerging challenges in the Chinese economy rather than to cause supply chain disruptions in external markets. By prioritizing its own economic and security interests, China's policies and practices did and will continue to impact trading partners, just like policies adopted by other economies for a lack of consideration of their global implications.
As part of the de-risking strategy, governments have every reason to pursue diversification of supply sources. However, to de-risk supply chain risks, cooperation is essential. Most of the mechanisms being developed under partnerships on supply chains, including those focused on CMs, can achieve better outcomes by involving China in the discussions and collaboration. This is not only because China remains a key player in global supply chains and a major trading partner with many countries including US allies. This is also because collaboration with China under an established framework such as IPEF and the WTO would provide the opportunity to incentivize China to enhance transparency and exchange of its policy and regulatory developments and engage in discussions of advanced environmental and labor standards, while disincentivizing it from non-market policies and practices and coercive actions. To the contrary, a confrontational strategy with ‘China being the risk’ at its core will only undermine rational policymaking and lead to mutually destructive and globally disruptive policies and practices, be it de-coupling or de-risking.
Acknowledgements
This author acknowledges the support by the research project ‘CPTPP Environmental Dispute Settlement Mechanism’ (project number: 23YJA820033), funded by the Humanities and Social Sciences Planning Fund of the Ministry of Education of P.R. China.
