Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 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.

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).

China's Unreliable Entity List Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 10 on 9 October 2025 designating 14 foreign entities — Dedrone by Axon Inc., DZYNE Technologies Incorporated, Elbit Systems of America LLC, Epirus Inc., AeroVironment Inc., Exelis Inc., Alliant Techsystems Operations LLC, BAE Systems Inc., Teledyne FLIR LLC, VSE Corporation, Cubic Global Defense, Recorded Future Inc., the Halifax International Security Forum, and TechInsights Inc. (with nine named subsidiaries) — for engaging in military-technical cooperation with Taiwan, harmful statements concerning China, and assisting foreign governments in suppressing Chinese enterprises. The measures (i) prohibit the listed entities from China-related import-export activity, (ii) ban new investment in Chinese territory, and (iii) for the first time under the UEL framework explicitly prohibit Chinese organisations and individuals from transmitting data or providing sensitive information to the listed entities. Issued the same day as MOFCOM/GAC Announcements No. 61/62 extending rare-earth export controls extraterritorially under a 0.1% de minimis content rule, the package marks the first UEL deployment targeting counter-drone original equipment manufacturers and the first to introduce a data-transmission restriction.

China's MOFCOM Unreliable Entity List Working Mechanism designated three US firms — Saronic Technologies, Aerkomm Inc., and Oceaneering International — on 25 September 2025, effective the same day, under Article 2 of the Provisions on the Unreliable Entity List (MOFCOM Order No. 4 of 2020) and citing the Foreign Trade Law, the National Security Law, and the Anti-Foreign Sanctions Law. MOFCOM's stated trigger is the firms' "so-called military-technical collaboration with China's Taiwan region." Measures bar the designees from China-related import/export activity and new investment in mainland China, with entry/work-permit restrictions on relevant management personnel.

China's State Council Taiwan Affairs Office announced on 5 June 2025 that it would impose punitive measures on Sicuens International Co Ltd (兆亿有限公司, transliterated "Zhaoyi"), a Taiwan-registered trading company whose responsible person, Shen Tucheng, is the father of Democratic Progressive Party legislator and "die-hard Taiwan independence" figure Shen Po-yang (Puma Shen). TAO spokesperson Zhu Fenglian said investigations found the company conducted trade and business cooperation with mainland Chinese enterprises to seek economic benefit, and stated the mainland "will never allow enterprises related to die-hard 'Taiwan independence' elements to seek profits on the mainland." The measure prohibits Sicuens International/Zhaoyi from any transactions or cooperation with mainland organizations, enterprises, or individuals, with further unspecified measures reserved.

China's MOFCOM Unreliable Entity List Working Mechanism designated six US firms on 9 April 2025, effective 12:01 Beijing time 10 April 2025, under MOFCOM Order No. 4 of 2020. Cited trigger: participation in arms sales to Taiwan or military-technology cooperation with Taiwan in disregard of China's stated opposition, "seriously harming China's national sovereignty, security and development interests." Measures prohibit the six entities from import/export activities related to China, new investments in China, and impose entry/work-permit restrictions on senior management.

China's MOFCOM Unreliable Entity List Working Mechanism designated 11 US drone-sector companies on 4 April 2025 — Skydio Inc., BRINC Drones Inc., Kratos Unmanned Aerial Systems Inc., Insitu Inc., Red Six Solutions LLC, SYNEXXUS Inc., Firestorm Labs Inc., HavocAI, Neros Technologies, Domo Tactical Communications LLC, and Rapid Flight LLC — citing military-technology cooperation with Taiwan in violation of China's One-China principle. Designations prohibit the 11 firms from import/export activity related to China, bar new investments in China, and restrict senior-executive entry. Issued on the same date as the MOFCOM heavy rare-earth export-licensing measure, the designations formed a paired retaliation package responding to the 2 April 2025 US "Liberation Day" reciprocal-tariff escalation. On 15 May 2025 MOFCOM suspended the UEL restrictions on all 11 companies for 90 days in line with the US-China Geneva tariff truce.

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 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 Unreliable Entity List Working Mechanism, led by MOFCOM, issued Announcement [2025] No. 1 on 2 January 2025 designating 10 US defense entities — five Lockheed Martin subsidiaries (Missiles and Fire Control, Aeronautics, Missile System Integration Lab, Advanced Technology Laboratories, Ventures), the Javelin Joint Venture (Raytheon/Lockheed Martin), Raytheon Missile Systems, and three General Dynamics units (Ordnance and Tactical Systems, Information Technology, Mission Systems) — as Unreliable Entities under the 19 September 2020 Provisions on the Unreliable Entity List, citing their participation in US arms sales to Taiwan. The measures prohibit the 10 firms from engaging in import/export activity related to China and from making new investments in China, and bar approval/renewal of work permits and stay/residence qualifications for their senior executives. This is the first multi-entity UEL designation under the 2020 Provisions and was issued the same day as the parallel MOFCOM Announcement [2025] No. 1 of the export-control bureau adding 28 US entities to China's Export Control List — together establishing a coordinated two-track countermeasure template against US defense and dual-use industry.