From “List-Based” to “Panoramic”: The Industrial Chain Logic and Global Spillovers of China’s New-Generation Industrial Policy

A Document Translated Ten Years Ago, and a Problem That Has Changed

Around 2016, discussions surrounding "Made in China 2025" were once quite focused: which industries were on the list, where localization rate targets were set, and which industrial powers would be the first to feel competitive pressure. The "heat map" covering major manufacturing powers published that year by the Mercator Institute for China Studies, as well as assessments successively released by the European Union Chamber of Commerce in China and the American Chamber of Commerce, all pointed to the same judgment: this was a systematic catch-up supported by state resources and aimed at specific advanced manufacturing fields.

Ten years later, the judgment offered by this study written by Rhodium Group for the American Chamber of Commerce is: the shape of the problem has changed.

The change that truly needs to be understood is not whether China is still subsidizing, but the boundary of policy. When intervention expands from an industry list that can be enumerated item by item to upstream raw materials, industrial equipment, downstream applications, services, and frontier technologies, the unit of analysis for industrial policy is no longer "whether a certain industry will be hit," but "which segment of the entire industrial chain still leaves room."

The Expansion of the Policy Framework: From Sectoral Intervention to Full-Chain Coverage

The report offers a rather blunt summary: China's industrial policy is evolving from targeted sectoral intervention into "an all-encompassing industrial policy" (an industrial policy of everything).

The essence of this formulation is three extensions of coverage.

Extending upstream. In areas such as critical minerals, silicon wafers, and magnetic materials, China already holds a dominant position. The policy goal is no longer to acquire these positions, but to extend and replicate this position across a broader range of industrial products.

Extending into mature industries. Even in mature industries with overcapacity and significant price pressure, the policy orientation is not to push for exit, but to continue supporting enterprises in upgrading production technology in order to compete for market share and lower production costs. Beijing has not abandoned mature industries; rather, it is pushing them toward higher segments of the value chain.

Extending into services and frontier technologies. The service sector was relatively neglected in earlier rounds of industrial policy, but visible progress has now been made in fields such as software, data processing, and drug research and development. At the same time, artificial intelligence, quantum technology, and future energy systems are seen as window periods that can open up a generational gap.

The last point deserves separate mention: these new technologies are no longer treated only as objects of R&D and innovation. Public procurement and state-owned enterprises are being used to create early demand at scale and provide deployment scenarios for new products. For a policy system accustomed to supply-side tools, shifting toward demand creation is a not-insignificant step change.

Reorganizing the Toolbox Under Constraints

The expansion of policy coverage is occurring in a tighter macroeconomic environment than a decade ago: slowing growth, weak domestic demand, rising fiscal pressure, and declining efficiency of capital allocation.

The conventional inference should be contraction. What the report describes is the opposite: re-centralization and stronger resource coordination.具体路径包括：加强对财政支出、银行信贷、资本市场与国有投资基金的统一掌控；整合政府引导基金并使其更紧密地对齐国家目标；通过定向再贷款工具与监管指引来引导银行信贷流向；清理浪费性或重复性的税收与财政补贴，地方层面尤为明显。

其中长期含义被报告点得很清楚：在经历了数十年的市场化之后，非市场考量正在被重新写入银行、国有企业与投资市场的运行逻辑。这有可能延长产业政策的有效期，但对整体经济活力与效率的长期影响需要单独计价。

效率折损：政策效力与稀释风险的赛跑

政策覆盖越广，单位资源的边际效力越容易下降。报告明确提示，产业政策扩展到日益宽泛的行业集合，存在稀释有效性的风险；国家对金融市场的更强影响，也可能进一步降低资源配置效率。

压力信号已经出现：企业利润率下滑、民间投资走弱、关键行业研发增长放缓。这些变量在短期内未必抵消产业层面的收益，但会逐步作用于生产率与长期增长潜力。

同样值得记录的还有需求端的缺口。报告指出，政策层已承认需要处理结构性失衡，但迄今的回应尚未达到转变增长模式所需的结构性改革力度；提振消费的努力也仍然有限，内需疲弱的底层问题基本未被触及。这构成了一个内在张力：供给端持续扩张，需求端修复有限。

全球外溢：从贸易份额到供应链依赖

中国产业与政策组合的全球影响，在过去三年明显加速。

报告给出的核心量化观察是：自2019年以来，制造业货物贸易顺差大约翻倍，达到约2万亿美元。这一扩张既来自出口上升，也来自进口替代的成功。不少观察者将其称为"中国冲击2.0"。

与上一轮冲击不同的是，这一次的外溢伴随着中国企业在海外市场的快速扩张，以及北京越来越频繁地使用政策工具来巩固其在全球价值链中的位置、对冲外国的多元化布局。

换句话说，竞争的场域正在从"谁能在中国市场卖出产品"，转向"谁能在中国体系之外建起替代性供应链"——而后者正是当前政策工具明确瞄准的方向。

对产业链的几点判断

把这些线索放在一起，可以得出几个偏中期的推论。

上游材料与中间品的议价结构继续向中国集中。 在关键矿产、硅片、磁材等已是主导地位的环节，政策资源的作用是防守与延伸，而非攻坚。

压力向装备与工业投入品传导。 当政策对象从终端产品延伸到工业设备，国产化压力会向上游装备环节扩散，这对长期依赖对华出口的欧洲、日本、韩国装备制造商构成结构性挑战。Global price pressure from mature industries is persistent. Because the policy orientation is to upgrade technology rather than cut capacity, cost declines and battles for market share will occur simultaneously, and price pressure will continue to spill over to comparable overseas capacity.

The form of service-sector going global may differ from manufacturing. In fields such as software, data processing, and drug R&D, cross-border modes are closer to service delivery and technology licensing, and their trade statistics characteristics and regulatory sensitivity differ from goods exports.

The technology gap remains the next concentrated direction for policy resources. The report also points out that in areas such as high-end semiconductors, advanced aerospace, and biomedicine, Chinese companies have not yet closed the technology gap. These areas are both the unfinished part of existing policies and the places most likely to receive increased future resource investment.

Variables to Track

For manufacturing enterprises, supply chain managers, and policy researchers, more effective than predicting the survival or abolition of individual policies is tracking the trajectory of several structural variables:

The actual investment direction and pace after the integration of government guidance funds; the scale and industry distribution of structural credit tools such as targeted relending; the speed at which public procurement and state-owned enterprises adopt new technologies such as artificial intelligence; the relative contribution of import substitution and export expansion to the manufacturing trade surplus; the trends in corporate profit margins, private investment, and R&D spending; and changes in import dependence in areas such as high-end semiconductors, aerospace, and biomedicine.

Conclusion

The report wrote a rather candid sentence in its preface: the current challenge does not stem from an intelligence gap. The documents have been translated, the reports have been published, and the warnings have been delivered to governments and industry leaders of major economies. The real problem lies in insufficient response—whether due to competing priorities, political constraints, or the judgment that "market forces will form checks and balances on their own."

This sentence applies equally to readers. The key to understanding China's new generation of industrial policy is not to ask whether a certain industry is still on the subsidy list, but to recognize that the coordinate system of intervention has changed: from tackling a few industries to laying out the entire industrial chain. What will truly determine the global industrial landscape next is who can run faster—policy execution capacity or efficiency losses.