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On 29 June 2026 China's Ministry of Commerce issued Announcement No. 27 [2026], adding 20 Japanese entities to the dual-use-item export-control Control List (受控名单) under the Dual-Use Export Control Regulations. The designated entities include four defense research institutes (National Institute for Defense Studies plus ground-, naval- and air-systems research bodies) and 16 companies, primarily Mitsubishi Electric and Mitsubishi Heavy Industries subsidiaries. The Control List designation imposes an absolute prohibition on exporting PRC-origin dual-use items — including rare earths and gallium/germanium/antimony-class strategic minerals — to the listed parties, and bars any third-country transfer of Chinese-origin dual-use items to them; ongoing supply activity must cease immediately, with exceptions only via special MOFCOM application. MOFCOM stated the action targets entities "involved in enhancing Japan's military capabilities."

China's Ministry of Commerce issued Announcement No. 23 of 2026 on June 22, 2026, adding 10 US entities to the Export Control Management List under the Export Control Law and Dual-Use Items Export Control Regulations. The listing prohibits Chinese exporters from supplying dual-use items to these entities and bars any global party from transferring China-origin dual-use goods to them; ongoing transactions are suspended pending MOFCOM approval. The 10 entities include the two largest non-Chinese rare earth producers — MP Materials Corp. (Mountain Pass, CA) and USA Rare Earth Inc. (Round Top, TX) — as well as eight US defence firms (Aveox, Red Cat Holdings, Teal Drones, IMSAR, Jaia Robotics, Ball Aerospace, Oshkosh Defense, L3Harris Maritime). MOFCOM explicitly framed the action as retaliation for the US DoD's June 8, 2026 update to the Section 1260H Chinese Military Companies list, which added ~80 Chinese parent firms and 188 affiliates.

On 2 May 2026, MOFCOM issued Announcement No. 21 of 2026 — the first concrete prohibition order ever issued under China's 2021 "Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures" (Blocking Rules) and the Anti-Foreign Sanctions Law (AFSL). The order prohibits any Chinese organisation, individual, or foreign party operating in China from recognising, enforcing, or complying with US sanctions imposed under Executive Orders 13902 and 13846 against five Chinese independent ("teapot") refineries — Hengli Petrochemical (Dalian) Refining Co., Ltd., Shandong Shouguang Luqing Petrochemical Co., Ltd., Shandong Jincheng Petrochemical Group Co., Ltd., Hebei Xinhai Chemical Group Co., Ltd., and Shandong Shengxing Chemical Co., Ltd. — all designated by OFAC for purchasing Iranian crude. The announcement is the first operational test of the framework built up across the AFSL (2021), the AFSL Implementation Regulations (Order 803, March 2025), and State Council Order 835 on Countering Foreign Unlawful Extraterritorial Jurisdiction (April 2026), and creates a direct compliance conflict for banks, insurers, traders, and shipping companies operating in or with China that had been winding down their exposure to the listed refineries.

Premier Li Qiang signed State Council Order No. 835 on 13 April 2026 promulgating the "Regulations of the People's Republic of China on Countering Foreign States' Unlawful Extraterritorial Jurisdiction" (20 articles), effective on the date of publication. The Regulations are the first State Council–level administrative regulation to operationalise the PRC's framework for identifying and countering foreign extraterritorial measures on a horizontal basis, complementing the 2021 Anti-Foreign Sanctions Law and the March 2025 AFSL implementation regulations. Article 5 establishes a State Council–led inter-agency coordination mechanism; Article 6 vests the State Council legal affairs department (the Ministry of Justice in practice) with authority to identify "improper" foreign extraterritorial measures and to grant exemptions; Article 8 authorises a new Malicious Entity List targeting foreign organisations and individuals that "promote or participate in implementing" such measures, with nine countermeasure categories spanning visa denial, asset freezing, trade restrictions and fines; Article 11 codifies an exemption-application channel under which Chinese persons facing conflicting legal demands may request approval to comply with foreign measures within a defined scope; Article 14 authorises a private right of action for harmed Chinese citizens and organisations to sue parties enforcing such measures; and Article 18 elevates enforcement beyond administrative penalties by referencing potential criminal liability.

Premier Li Qiang signed State Council Order No. 834 on 31 March 2026 promulgating the "Provisions on Industrial Chain and Supply Chain Security" (18 articles), adopted at the State Council executive meeting on 13 March 2026 and effective on the date of publication. The Provisions are the first dedicated PRC administrative regulation on industrial- and supply-chain security and consolidate authorities drawn from the National Security Law, Foreign Relations Law, Anti-Foreign Sanctions Law, and Foreign Trade Law into a horizontal defensive framework. They establish a cross-agency coordination mechanism spanning roughly 15 central departments (industrial, security, cyberspace, customs and financial regulators) plus provincial governments; create a security-investigation system; and vest broad countermeasure authority over both foreign states (Article 14 — import/export prohibitions and special levies) and foreign organisations and individuals (Article 15 — import/export bans, China-investment bars, transaction prohibitions, entry bars and revocation of work or residence permits, with extension to effectively-controlled subsidiaries). The Provisions also impose compliance, information-sharing, strategic-reserve and emergency-response obligations on PRC organisations and individuals, and authorise requisition, mandated production and directed transportation in the event of supply-chain disruption.

On 24 February 2026 China's Ministry of Commerce simultaneously issued Announcement No. 11 and Announcement No. 12 [2026], activating for the first time the Control List (受控名单) mechanism under Article 28 and the Watch List (关注名单) mechanism under Article 26 of the Dual-Use Export Control Regulations (effective 1 December 2024), designating 40 Japanese entities in total. The Control List (20 entities, led by Mitsubishi Heavy Industries Shipbuilding Co.) imposes an absolute prohibition on any person or entity worldwide supplying PRC-origin dual-use items to listed parties; the Watch List (20 entities, led by SUBARU Corporation) bars general licensing and requires exporters to file risk assessments and non-military-use commitments. MOFCOM framed both measures as a response to Japan's "remilitarization" trajectory, escalating well beyond the blanket enhanced- review framework established by Announcement No. 1 [2026] in January.

On 6 January 2026 China's Ministry of Commerce issued Announcement No. 1 [2026] "On Strengthening Export Controls on Dual-Use Items to Japan" (商务部公告2026年第1号), the first PRC export-control instrument to single out a named country other than the United States. Effective immediately on publication with no wind-down period, the measure prohibits export of all dual-use items under PRC export-control law where the end-user is the Japanese Ministry of Defense or Self-Defense Forces, the end-use is Japanese military, or — under a novel catch-all standard — the transaction would "enhance Japan's military capabilities." The standard is explicitly extraterritorial, covering transfers of PRC-origin dual-use items through third countries and in-country transfers where the end-user / end-use falls within scope. The political trigger was Japanese PM Takaichi's November 2025 Diet remarks framing a Taiwan contingency as a Japanese "survival-threatening situation" justifying SDF deployment.

China's Ministry of Foreign Affairs announced on 26 December 2025 that it is imposing countermeasures under Articles 3, 4, 5, 6, 9 and 15 of the Law of the People's Republic of China on Countering Foreign Sanctions against 20 US defense-related companies and 10 senior executives, in response to the Trump administration's 18 December 2025 announcement of roughly $11.1bn in arms sales to Taiwan — the largest single US weapons package for the island to date. Measures freeze the named entities' assets within China, prohibit organizations and individuals in China from transacting or cooperating with them, and deny visas/entry to the named executives. This is a Foreign Ministry Anti-Foreign Sanctions Law designation, distinct in legal basis from MOFCOM's parallel Unreliable Entity List mechanism used in prior 2025 Taiwan-arms-sale tranches (e.g. the 9 April 2025 six-firm UEL listing).

On 11–12 December 2025, China's National Development and Reform Commission (NDRC) convened a special meeting with major phosphate fertiliser producers, traders, and industry associations, instructing them to suspend phosphate fertiliser exports in principle until August 2026 to concentrate supply on the domestic market and stabilise prices ahead of the 2026 spring planting season. The measure covers diammonium phosphate (DAP), monoammonium phosphate (MAP), triple superphosphate (TSP), and compound NPK fertilisers. China supplied roughly 40% of global phosphate fertiliser exports before the ban; Chinese export volumes in Q1 2025 fell to ~111,000 t versus a three-year average of 785,000 t for the same period.

On 9 December 2025, China's Ministry of Commerce (MOFCOM) and General Administration of Customs jointly issued Announcement No. 79 of 2025, reinstating an export-licence management system for ~300 HS-coded steel products effective 1 January 2026. Exporters must obtain a per-contract licence supported by a manufacturer-issued product quality inspection certificate; licences are issued by MOFCOM (for centrally-administered SOEs) and provincial / sub-provincial commerce departments. The regime is the first reinstatement of Chinese steel-export licensing in 16 years (since 2009) and applies the export-licensing instrument — previously used for critical minerals and dual-use goods — to a non-critical bulk commodity for the first time.

MOFCOM Announcement No. 68 of 2025 (商务部公告2025年第68号), issued on 26 October 2025, sets the application requirements and procedures for state-owned trading enterprises (STEs) authorised to export tungsten, antimony and silver during the 2026-2027 cycle. The notice formalises a quota review and joint-approval gate operated through the Key Export Supervision Catalog under MOFCOM's foreign-trade STE authority — distinct from the Export Control Law dual-use regime used in Announcement No. 10 of February 2025. Silver is added for the first time to the STE-managed list, framed by MOFCOM as defence of strategic supply for defence, electronics and photovoltaics. Approved-exporter lists were published in a follow-on review-results notice; the new regime applies to export shipments dated 1 January 2026 onwards.

China's State Council General Office issued Guobanfa [2025] No. 34 ("Notice on Implementing Domestic Product Standards and Related Policies in Government Procurement") on 28 September 2025, effective 1 January 2026. The notice applies a 20% price deduction to domestic-product bids when evaluating government procurement tenders; suppliers whose domestic-content cost share reaches 80% or more of total product cost get the deduction applied to their entire quoted price rather than only the domestic-content portion. Coverage is economy-wide across the government's Goods Classification Directory (Global Trade Alert separately tagged natural/man-made textile fibres and yarn under this measure), with narrow carve-outs for real estate, cultural relics, agricultural/forestry/fishery products, minerals, utilities, and food/tobacco raw materials. The Ministry of Finance published implementing guidance (Caiku [2025] No. 30) shortly after.

China's State Council promulgated Order No. 818 on 28 September 2025 (effective 1 May 2026), establishing a comprehensive dual-track regulatory framework for biomedical new technologies — defined as techniques operating at the cellular or molecular level not yet clinically applied in China, covering cell therapy, gene editing, CAR-T, stem-cell, xenotransplantation, brain-computer interfaces, and nucleic-acid therapies. The regulation creates two parallel pathways: a traditional NMPA drug/device registration route and a new NHC-supervised clinical-research-to-commercialization track applicable to highly personalised or rare-disease therapies meeting staged safety and efficacy thresholds. Commercialisation under the NHC track is initially restricted to accredited Grade-3A medical institutions without full NMPA marketing approval, potentially accelerating patient access for qualifying technologies by 5–8 years relative to the standard registration pathway.

On 23 April 2025 CMOC Group (HKG:3993) announced the acquisition of TSXV-listed Lumina Gold Corp — 100% owner of the Cangrejos (Los Cangrejos) gold-copper project in El Oro Province, southwestern Ecuador — via a court-sanctioned plan of arrangement at C$1.27/share (C$581M / ~USD 420M); the transaction closed on 24 June 2025 through a Singapore subsidiary, making Cangrejos Ecuador's largest primary gold deposit under full Chinese operational control. On 27 April 2026 CMOC's Ecuadorian subsidiary ODIN Mining del Ecuador signed a 26-year exploitation contract with Ecuador's Ministry of Energy and Mines committing >$1.7B in total investment (~$54M advance royalties, $34M paid on signing); commercial production is targeted for 2028 at ~11.5 t/yr gold (~370,000 oz/yr), making the state-projected total revenues $4.39B over the mine life. The acquisition extends CMOC's critical-mineral portfolio — anchored in DRC cobalt/copper — into Ecuadorian gold and copper, concentrating a globally significant undeveloped gold-copper deposit under Chinese operational control ahead of the competing 2026 Ecuador–US Critical Minerals Bilateral Framework.

China's Ministry of Commerce and General Administration of Customs announced on 4 April 2025 export licensing requirements on seven medium and heavy rare-earth elements: samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium. Exporters must apply for individual licences citing the end-user and end-use, with licences granted at MOFCOM's discretion. The announcement came two days after the 2 April Trump reciprocal-tariff package and was widely interpreted as a proportional response. Unlike the December 2024 Ga/Ge/Sb ban this is not US-specific on its face — but in practice licence approvals through April-June 2025 were heavily skewed away from US-bound shipments.

Premier Li Qiang signed State Council Order No. 803 on 23 March 2025 promulgating the "Regulations on Implementation of the Anti-Foreign Sanctions Law of the People's Republic of China" (22 articles), effective on the date of publication (24 March 2025). The Regulations operationalise the 2021 Anti-Foreign Sanctions Law by clarifying the scope of countermeasure tools — explicitly extending "other property" subject to seizure to cash, bank deposits, securities, equity, intellectual property and accounts receivable, and listing the specific transaction and cooperation activities that may be prohibited or restricted (education, S&T, legal services, environment, trade, culture, tourism, health, sports, data and cross-border data transfers). They define inter-agency procedure, evidence and notice requirements for designations, and bind PRC organisations and individuals — including foreign-invested entities operating in China — to implement countermeasures, with sanctions including exclusion from government procurement, import/export and cross-border-data restrictions, and exit/stay restrictions for responsible persons.

MOFCOM and the General Administration of Customs jointly issued Announcement No. 10 [2025] on 4 February 2025, imposing dual-use export-licence controls on items related to tungsten, tellurium, bismuth, molybdenum and indium under the Export Control Law and Dual-Use Items Export Control Regulations. The controls cover metals, alloys, powders, compounds and related processing technologies across roughly 25 listed item categories (41 HS 10-digit codes). The measure is global in scope but was issued the same day China announced 10-15% retaliatory tariffs on US LNG, coal, crude and farm equipment in response to the Trump administration's 10% fentanyl-tariff hike — extending the MOFCOM critical-minerals control regime beyond gallium/germanium/graphite/antimony/heavy-REEs.

China's Unreliable Entity List (UEL) Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 2 on 4 February 2025, designating PVH Group (parent of Calvin Klein and Tommy Hilfiger) and Illumina Inc. (US genomics / gene-sequencing equipment maker) as Unreliable Entities under the 2020 UEL Provisions, citing violations of normal market-transaction principles and discriminatory measures against Chinese enterprises. PVH was cited for its Xinjiang-cotton sourcing boycott (MOFCOM probe launched September 2024); Illumina was cited for restricting Chinese customers' access to gene-sequencing equipment. The announcement was issued on the same day as China's IEEPA-retaliation tariff package (10–15 % on US coal, LNG, crude oil, agricultural goods, and autos), making it the first UEL listing of a Western consumer-brand / retail company and the first combining a UEL designation with a subsequent sector-specific export prohibition (gene sequencers, imposed 28 February 2025).

China's Ministry of Commerce issued Announcement 2025 No. 3 on 9 January 2025, the Final Determination of its Trade and Investment Barrier (TIB) investigation into the European Commission's enforcement practices under the EU Foreign Subsidies Regulation (FSR). MOFCOM concluded that EC practices in FSR investigations targeting Chinese enterprises in rail transport, photovoltaics, wind energy, and security-equipment public procurement constitute trade and investment barriers under Article 3 of China's Rules on Trade and Investment Barrier Investigations (对外贸易壁垒调查规则). The determination documents €20.88 billion in estimated economic losses — including €10.18 billion from abandoned bids — and finds de-facto discrimination against Chinese SOEs relative to investors from other jurisdictions. MOFCOM committed to taking "necessary measures" including bilateral consultations, multilateral dispute settlement, or "other appropriate measures" to safeguard Chinese enterprises' legitimate rights and interests.

China's Ministry of Commerce announced on 3 December 2024 (MOFCOM Announcement No. 46 of 2024) a formal ban on dual-use exports to the United States of gallium, germanium, antimony and superhard materials including diamond and cubic boron nitride. The measure also imposed strict end-use review on graphite exports to the US, with extra scrutiny of military end-uses. It came one day after BIS issued a major export- control package on 2 December 2024 expanding controls on Chinese semiconductor equipment and adding 140 entities to the Entity List, and was framed by MOFCOM as a national- security countermeasure.

Premier Li Qiang signed State Council Decree No. 792 on 19 October 2024 promulgating the Regulations of the People's Republic of China on Export Controls for Dual-Use Items, with effect from 1 December 2024. The regulation, organised in six chapters and 50 articles, consolidates the previously fragmented nuclear / biological / chemical / missile dual-use control regimes into a single State Council framework operationalising the 2020 Export Control Law. It introduces a control-list / temporary-control / watchlist architecture, a statutory end-user / end-use commitment regime, transit / transhipment / re-export controls, extraterritorial reach over PRC items downstream, and explicit linkage to the Anti-Foreign Sanctions Law. On 15 November 2024 MOFCOM, MIIT, GAC and SCA jointly issued Announcement No. 51 of 2024 publishing the consolidated Dual-Use Items Export Control List with a unified five-character ECCN-style coding system, also effective 1 December 2024.

China's Ministry of Commerce and General Administration of Customs jointly issued Announcement No. 33 of 2024 on 15 August 2024, imposing an export licensing regime on antimony ore, antimony metal, antimony oxides (purity ≥99.99%), organic antimony compounds, antimony hydride, indium antimonide, and gold-antimony smelting technology, effective 15 September 2024. The announcement also covers six-sided top-press equipment used in superhard-materials (diamond, cubic boron nitride) production. China accounts for approximately 47% of global antimony mine output and an estimated 75-80% of refined antimony supply; in the months following implementation, Chinese antimony export volumes fell by approximately 97% and global antimony trioxide spot prices roughly doubled.

China registered the National Integrated Circuit Industry Investment Fund III Co., Ltd. ("Big Fund III") in Beijing on 24 May 2024 with RMB 344 billion (~USD 47.5 billion) of registered capital — the largest single capital raise of the three Big Fund phases (Phase I 2014: RMB 138.7bn; Phase II 2019: RMB 204bn). Nineteen state-owned investors contribute, led by the Ministry of Finance (17% / RMB 60bn) and the six largest state-owned commercial banks (ICBC, ABC, BoC, CCB ~6.25% each at RMB 21.5bn; BoCom RMB 20bn; PSBC RMB 8bn). Duration 15 years (24 May 2024 → 23 May 2039). The fund explicitly targets the chokepoints exposed by US BIS October 2022/2023/2024 controls — semiconductor manufacturing equipment, advanced memory (HBM/DRAM), AI accelerators, and third-generation compound semiconductors (SiC, GaN).

Order of the State Council No. 785, adopted at the 31st executive meeting on April 26, 2024 and effective October 1, 2024, is the first comprehensive statutory regulation governing China's entire rare earth industry chain — from mining and smelting through product circulation and import/export. It replaces the 2012 administrative-regulation framework with higher-authority State Council instruments, centralising quota allocation under MIIT+NDRC+MNR, establishing a mandatory national rare earth traceability platform, and extending domestic controls to foreign-origin feedstock refined in China. This regulation is the umbrella enabling instrument for all downstream MOFCOM and MIIT rare earth export-control measures enacted from 2024 onward.

On 13 March 2024 the State Council issued the Action Plan on Promoting Large-Scale Equipment Renewal and Consumer Goods Trade-In as Guo Fa [2024] No. 7, distributed by NDRC alongside ten implementing ministries. Branded the "Two New" (两新) initiative, it is the flagship Xi/Li-era domestic-demand industrial-policy instrument structured around four action lines (equipment renewal, consumer-goods trade-in, recycling and circular utilisation, standards uplift) with twenty specific tasks and 2027 quantitative targets including ≥25% increase in equipment investment vs 2023 across industry, agriculture, construction, transport, education and healthcare. Funded by CNY 150bn of ultra-long-term special treasury bonds in 2024, expanded to CNY 300bn earmarked in 2025, the programme drove >CNY 1.3 trillion of consumer-goods trade-in transactions (autos, appliances, home furnishings, e-bikes) in its first year and is the central pillar of Beijing's response to the property-sector slowdown.

China's Ministry of Commerce and General Administration of Customs jointly announced (Announcement No. 33 of 2023) export-licensing controls on graphite products, effective 1 December 2023. The regime covers natural flake graphite and products thereof (including spherical graphite and graphite powder used in lithium-ion battery anodes) as well as high-purity, high-hardness, and high-strength synthetic graphite materials. Exporters must obtain dual-use-item licences from MOFCOM citing end-user and end-use; licences are granted at MOFCOM's discretion. The announcement came three days after the 17 October 2023 BIS advanced-chip-controls expansion, continuing the proportional-response pattern established with Ga/Ge in July.

China's Ministry of Commerce and General Administration of Customs jointly announced an export licensing regime covering eight gallium-related items (including gallium metal, gallium arsenide, gallium nitride wafers and ingots) and six germanium- related items (including germanium metal, germanium oxide, germanium tetrachloride). Effective 1 August 2023, exporters must obtain a dual-use-item licence from MOFCOM citing the end-user and end-use, with licences granted at MOFCOM's discretion. The measure was framed as protecting national security and interests, though the timing immediately followed the Dutch ASML DUV controls and US chip-equipment escalations.

Ganfeng Lithium (HKG:1772 / SZE:002460), China's largest lithium producer, has accumulated controlling interests in Argentina's most significant lithium brine operations through a series of transactions since 2019. The key assets are: **Cauchari-Olaroz (Jujuy Province):** Ganfeng holds 46.5% of the project alongside Lithium Americas Corp (53.5%), which commenced commercial production in mid-2023. It is Argentina's largest lithium brine operation, targeting 40,000 tonnes per year of battery-grade lithium carbonate. Ganfeng provides offtake for substantially all lithium carbonate produced and has rights to purchase Lithium Americas' share of output at market prices. **Pozuelos-Pastos Grandes (PPG) basin (Salta Province):** Ganfeng agreed in 2024-2025 to consolidate the PPG lithium basin through a new joint venture in which Ganfeng holds 67% and Lithium Argentina (spun off from Lithium Americas) holds 33%. The basin is one of Argentina's largest undeveloped lithium brine resources. The SEC filing confirming this consolidation was published in April 2025. Combined, Ganfeng's Argentine lithium position gives it a structurally significant share of Argentina's battery-grade lithium output and exploration pipeline — positioned within the lithium triangle alongside Chilean and Bolivian deposits but with operational production at Cauchari-Olaroz already running. The investments were financed through a combination of Ganfeng's corporate balance sheet and China Development Bank-linked project finance. Ganfeng has also established its own lithium hydroxide refining capacity in China fed from the Cauchari-Olaroz brine, creating a vertically integrated supply chain from Argentine salar to Chinese battery-grade product.

The Personal Information Protection Law of the People's Republic of China (中华人民共和国个人信息保护法 — PIPL) was adopted at the 30th meeting of the 13th NPC Standing Committee on 20 August 2021 and entered into force on 1 November 2021, constituting the third and final pillar of China's cybersecurity and data-governance regulatory trinity alongside the Cybersecurity Law (2016) and the Data Security Law (2021). The PIPL is China's comprehensive personal-information statute establishing consent-based and necessity-based legal bases for PI processing, a tiered cross-border personal-data transfer regime (CAC security assessment / PI protection certification / Standard Contractual Clauses), extraterritorial application (Art. 3) to non-Chinese controllers offering services to or analysing the behaviour of PRC residents, and a heightened protection regime for sensitive personal information and data of minors under 14. It mandates data-protection impact assessments, personal-information-protection-officer obligations at designated handlers, breach notification, and a full suite of data-subject rights including access, rectification, deletion, portability, objection, and automated- decision-making opt-out. Article 53 requires overseas controllers to establish a domestic representative or designated entity in China, providing a domestic enforcement counterparty.

The Law of the People's Republic of China on Countering Foreign Sanctions was adopted at the 29th meeting of the Standing Committee of the 13th NPC on 10 June 2021 (Presidential Order No. 90, President Xi Jinping) and entered into force on the same day. Comprising 16 articles, it establishes the unified statutory framework for China's countermeasure regime against foreign states or organisations that "violate international law and basic norms of international relations" by imposing discriminatory restrictive measures against Chinese citizens and organisations — the parent authority under which every China countermeasure-list, Unreliable Entity List, blocking-statute, and supply-chain-security instrument in the IPTM register operates. Article 6 enumerates the countermeasure toolbox (visa denial, asset freezes, transaction prohibitions, and "other necessary measures"); Article 12 is the blocking-statute provision that prohibits PRC persons from implementing foreign discriminatory measures — first operationalised in May 2026 against five US-sanctions-compliant refineries.

The Data Security Law of the People's Republic of China (中华人民共和国数据安全法) was adopted at the 29th meeting of the 13th NPC Standing Committee on 10 June 2021 and entered into force on 1 September 2021, constituting the second pillar of China's cybersecurity and data-governance regulatory trinity alongside the Cybersecurity Law (2016) and the Personal Information Protection Law (2021). The DSL establishes a tiered data-classification regime — "important data" and "national core data" — with escalating security obligations including risk assessment, risk monitoring, breach reporting, and classified-protection requirements for data handlers. It introduces a data-export security review for "important data" generated or collected within China, the statutory parent authority operationalised by the 2024 CAC Cross-Border Data Flow Provisions, and enacts a §36 blocking statute prohibiting Chinese organisations and individuals from transferring data stored in China to foreign judicial or law-enforcement authorities without prior PRC government approval.

The Export Control Law of the People's Republic of China was adopted by the Standing Committee of the 13th National People's Congress on 17 October 2020 (Presidential Order No. 58) and entered into force on 1 December 2020. Comprising 5 chapters and 49 articles, it establishes the unified statutory framework governing China's export-control regime over dual-use items, military items, nuclear items, and other goods, technologies, services, and data whose export could affect national security or China's non-proliferation obligations. The law introduces comprehensive licensing requirements, end-user and end-use certification, deemed-export and re-export controls with extraterritorial reach, a Controlled Entities List (CEL) with matching-entity restrictions, and substantial criminal and administrative penalties — and it is the parent statutory authority under which every China export-control implementing instrument in the IPTM register operates.

MOFCOM Order No. 4 of 2020, issued and effective 19 September 2020, establishes the Unreliable Entity List (UEL / 不可靠实体清单) regime — China's primary countermeasure framework for designating foreign companies, organisations, and individuals that are deemed to endanger Chinese national sovereignty, security, or development interests, or that apply discriminatory measures against Chinese entities in violation of normal market principles. The UEL inter-ministerial Working Mechanism, administered through MOFCOM, may impose restrictions or prohibitions on the designated entity's China-related import/export activities, investment in China, and entry or stay of senior personnel in China, as well as fines. Promulgated under the Foreign Trade Law of the PRC and the National Security Law of the PRC, the Provisions serve as the statutory parent for every UEL designation announcement since 2023, and operate as the structural peer of the US BIS Entity List / OFAC SDN architecture and the simultaneously promulgated Anti-Foreign Sanctions Law framework.

On 15 March 2019, the Second Session of the 13th National People's Congress adopted the Foreign Investment Law of the People's Republic of China (FIL), effective 1 January 2020. The statute replaced the prior tripartite FDI regime — the 1979 Equity Joint Venture Law, the 1986 Wholly Foreign-Owned Enterprise Law, and the 1988 Contractual Joint Venture Law (collectively the "Three Laws") — with a unified legal framework covering all foreign investment in China. The FIL establishes a pre-establishment national treatment plus negative-list regime jointly administered by NDRC and MOFCOM, a Foreign Investment Information Reporting System replacing the former case-by-case approval regime, a national security review mechanism (China's CFIUS equivalent, codified at Art. 35), and Art. 22 technology-transfer prohibition protections. The State Council Implementation Regulations (Order No. 723, promulgated 26 December 2019) entered force on the same date as the FIL.

On 26 July 2018 the Serbian government agreed to sell a 63% stake in RTB Bor — the state-owned copper mining complex in eastern Serbia — to Zijin Mining Group (HKG:2899) for approximately USD 350 million plus a committed investment of USD 1.26 billion over five years. The transaction closed on 24 September 2018 after Chinese MOFCOM and Serbian government approvals. RTB Bor operates the Bor open-pit copper mine and the Čukaru Peki underground mine. Under Zijin's management, combined annual copper output reached 296,000 tonnes in 2025, making Zijin the second-largest copper producer in Europe after KGHM (Poland). The complex also produces significant gold as a by-product. The acquisition was facilitated by the China-Serbia comprehensive strategic partnership and BRI connectivity framework. The Serbian government accepted Chinese investment at a discount to assessed asset value in exchange for committed capital expenditure in a region with limited Western private-sector appetite for brownfield copper. EU membership negotiations and EU state-aid rules complicated alternative European financing structures. Zijin financed the acquisition through a combination of corporate balance sheet and China Development Bank-syndicated loans. The Čukaru Peki mine, which was not included in the initial RTB Bor asset base, received a separate Zijin investment commitment exceeding USD 800 million.

The Cybersecurity Law of the People's Republic of China (中华人民共和国网络安全法) was adopted at the 24th meeting of the 12th NPC Standing Committee on 7 November 2016 and entered into force on 1 June 2017, establishing the foundational legal framework for network security governance across all sectors. The law creates the Critical Information Infrastructure Operator (CIIO) designation and protection regime administered by the Cyberspace Administration of China (CAC), mandates data localisation for personal information and important data collected or generated by CIIOs in China, and establishes cross-border data-transfer security assessment requirements under Article 37 — the provision later operationalised by DSL 2021, PIPL 2021, and the 2024 CAC Cross-Border Data Flow Provisions. The CSL introduced multi-level protection scheme (等级保护制度 / MLPS) obligations for all network operators and network-product/service security-review procedures, under which CAC triggered the cybersecurity review of Didi Global in 2021 and the exclusion of Micron's products from Chinese critical-infrastructure projects in 2023.

On 9 May 2016 CMOC Group (China Molybdenum Co., HKG:3993 / SHA:603993) signed agreements to acquire Freeport-McMoRan's 56% stake in Tenke Fungurume Mining (TFM) in the Democratic Republic of the Congo for USD 2.65 billion, with additional financing from China Development Bank. A concurrent transaction acquired TF Holdings' 24% stake, bringing CMOC's total to 80% with Gécamines retaining 20%. The transaction closed on 16 November 2016 following regulatory approvals from the DRC Ministry of Mines, the US CFIUS (approved without conditions), and Chinese MOFCOM. Tenke Fungurume is the world's second-largest cobalt mine and fifth-largest copper mine, located in Lualaba Province. At the time of acquisition it produced approximately 16,000 tonnes of cobalt per year (hydroxide) and 180,000 tonnes of copper cathode, representing roughly 20% of global mined cobalt supply. CMOC subsequently expanded production to approximately 50,000 tonnes of cobalt per year by 2023-2024 through the Kisanfu (KFM) discovery development — bringing combined TFM+KFM output to ~115,000 tonnes of cobalt annually, or roughly 38% of DRC cobalt production and approximately 25% of global supply from a single operator. The acquisition was the largest Chinese overseas mining transaction of 2016 and established China's dominant structural position in the cobalt supply chain at the mine level — upstream of both DRC export controls (ARECOMS quota system, filed 2025-02-22) and Chinese processing/re-export controls on battery-grade cobalt compounds. CMOC is simultaneously the world's largest cobalt producer and an entity subject to Chinese government export licensing for the same materials — a concentration structure without precedent in critical minerals. The China Development Bank provided a $2.68 billion loan facility financing the majority of the acquisition, making this an explicit policy-bank-backed strategic asset purchase consistent with NDRC guidelines on overseas critical mineral investment priorities. Sinosure provided political-risk insurance cover on the DRC exposure.

On 26 November 2013 a Chinese consortium led by MMG Limited (HKG:1208, the listed mining arm of China MinMetals Corporation) agreed to acquire the Las Bambas copper project in Apurímac, Peru from Glencore PLC for USD 5.85 billion. The sale was completed on 7 April 2014. MMG holds 62.5% of the consortium; CITIC Metal holds 15%; Guoxin International holds 22.5%. All three are Chinese state-linked entities. Las Bambas is one of the world's largest copper deposits. Since commencing production in 2016 it has produced approximately 300,000-400,000 tonnes of copper concentrate per year, representing roughly 1-1.5% of global mined copper supply and approximately 10% of Peru's total copper exports. Peru is the world's second-largest copper producer (~10% global supply), so Las Bambas is a material share of the Andean copper complex. The acquisition was MOFCOM-directed: as a condition of approving the Glencore-Xstrata merger in 2013, China's Ministry of Commerce required Glencore to divest Las Bambas to a Chinese buyer within 12 months of merger completion. This is the definitive case of Chinese antitrust authority being used as an instrument of resource-acquisition policy — MOFCOM leveraged deal approval to transfer a world-class copper asset to Chinese state-linked ownership. Las Bambas has been the source of persistent community conflicts in Apurímac Province, with road blockades in 2022-2023 halting production for extended periods and bringing the Peru government into direct negotiation with MMG and local communities. China's policy-bank financing (CDB-backed) for the acquisition underpins the ongoing operation despite these disruptions.