Industrial Policy & Trade Monitor· 2679 actions· ✨ 92 recent

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 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.

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.

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.

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.

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.

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.