2026년 중국의 대일본 이중용도 품목 수출통제 조치의 함의와 시사점

This paper aims to analyze the process through which China’s export control policy has shifted from a trade management instrument to a national security–oriented strategic tool, focusing on the export control measures on dual-use items that China imposed specifically on Japan on January 6, 2026, and to derive the corresponding policy implications. Since its accession to the World Trade Organization (WTO), China has utilized export restrictions on key resources such as raw materials and rare earth elements in connection with political and diplomatic objectives, and these measures have twice been found to be inconsistent with WTO rules through dispute settlement processes. Nevertheless, China has continued to strengthen controls over strategic mineral resources, including rare earths, and in particular has established an institutional framework encompassing dual-use items following the enactment of its Export Control Law. Against this background, this paper examines the 2026 export control measures on dual-use items targeting Japan and demonstrates that China’s export controls function not merely as trade regulations but as economic security instruments combining national security and geopolitical considerations. These measures target strategic core resources, including rare earth elements, and are qualitatively distinct from previous export restrictions on raw materials and rare earths in that they extend the scope of control to technologies, equipment, personnel, and extraterritorial products. As such, they represent a case illustrating China’s institutionalization of export controls as a national security–centered strategic policy tool.