Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

The Office of the United States Trade Representative released the 2026 Special 301 Report on 30 April 2026, designating Vietnam as a Priority Foreign Country (PFC) — the most severe category under Section 182 of the Trade Act of 1974 (19 U.S.C. § 2242). This is the first PFC designation since Ukraine held the status from 2013 through 2015, a gap of approximately 11 years. The PFC designation triggers a statutory 30-day window (expiring ~30 May 2026) within which USTR must decide whether to initiate a Section 301 investigation under 19 U.S.C. § 2412(b)(2)(A), which could lead to tariffs, withdrawal of trade benefits, or other Section 301 enforcement remedies against Vietnam. Separately, the EU was added to the Watch List for the first time, citing AI training-data, geographical-indications, and customs-enforcement concerns.

On 21 April 2026 the European Commission issued a conditional clearance under the EU Foreign Subsidies Regulation (FSR, Regulation 2022/2560), requiring the exclusion of CRRC (China's largest rolling-stock manufacturer) from the Lisbon Metro Violet Line procurement — the first-ever FSR procurement remedy ordering a Chinese supplier exclusion from a specific EU public contract. The Commission found that CRRC received foreign subsidies enabling it to submit an unduly advantageous tender, and as a condition of clearance mandated CRRC's removal from the tender. CRRC was replaced by PESA (Polish rail manufacturer) as the selected bidder. Unlike the 2024 Bulgaria/CRRC case (FSP.100147) where CRRC voluntarily withdrew before a formal decision, the Lisbon case produced the first binding FSR exclusion remedy, establishing mandatory supplier-removal as an available enforcement outcome in EU public procurement.

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.

On 3 February 2026 the European Commission opened an in-depth Phase II investigation under the Foreign Subsidies Regulation (FSR) — the second FSR ex officio case and the first targeting the renewable-energy wind-OEM sector — into whether Xinjiang Goldwind Science & Technology Co., Ltd. and its EU affiliates received Chinese foreign subsidies (grants, preferential tax treatment, and state-bank preferential financing) that distort competition for wind-turbine supply and services in the EU internal market. The case (FS.100143) follows the April 2024 preliminary-review opening and subjects Goldwind to an 18-month Phase II investigation with potential redressive-measures decision. The action structurally extends the FSR enforcement perimeter from security equipment (Nuctech, FS.100068) into the green-transition energy-equipment supply chain.

On 9 February 2026 the UK Office of Financial Sanctions Implementation (OFSI) published a comprehensively revised enforcement and monetary-penalties guidance following its July–October 2025 public consultation. The update introduces a Settlement Scheme (20% penalty discount for subjects who agree not to contest OFSI's findings within 30 business days), an Early Account Scheme (up to 20% discount for legal persons providing a timely senior-attested factual account), a revised voluntary-disclosure framework (maximum discount cut from 50% to 30% and renamed to cover both prompt self-reporting and full cooperation), a four-level case-assessment seriousness matrix (severity × conduct), and fixed monetary penalties of £5,000 and £10,000 for information, reporting, and licensing offences. A planned legislative amendment (requiring primary legislation) will subsequently double the statutory civil monetary-penalty cap from £1m / 50%-of-breach to £2m / 100%-of-breach; in the interim the Policing and Crime Act 2017 caps remain in force. The revised guidance is the foundational enforcement architecture for all UK financial-sanctions programs (Russia, Iran, DPRK, Syria, Belarus, Myanmar, and 10+ additional regimes).

The European Commission adopted Communication C(2026) 43 final on 9 January 2026, issuing the first formal interpretive guidelines on the Foreign Subsidies Regulation (FSR, Regulation (EU) 2022/2560). The guidelines codify a four-pillar analytical framework — distortion assessment, public-procurement distortion test, balancing test, and ex officio call-in scope — that DG COMP will apply in every future FSR enforcement proceeding. As the operational blueprint for the FSR regime, the guidelines materially shape Chinese SOE and Gulf SWF EU-market access planning for concentrations, public-procurement tenders, and sub-threshold transactions.

Section 851 of the FY 2026 National Defense Authorization Act (P.L. 119-60), signed December 18, 2025, prohibits US federal agencies from procuring biotechnology equipment or services from designated "biotechnology companies of concern" (BCCs), and bars federal contractors from using such equipment/services in work performed under federal contracts, grants, or loans. The final enacted text ties initial BCC designations to DoD's existing §1260H Chinese-military-company list (which currently includes BGI and MGI, but not WuXi AppTec or WuXi Biologics) and directs OMB to designate additional BCCs within one year of enactment; operational prohibitions activate 60-90 days after FAR revision, with a five-year grandfather period for pre-existing contracts — enforcement is expected to begin in 2027-28. The legislation is the successor to H.R.8333 (118th Congress, House-passed September 2024 but stalled in the Senate before adjournment) and represents the first enacted US federal-procurement biotech-supply-chain-resilience statute.

Türkiye's Grand National Assembly adopted Law No. 7552 (İklim Kanunu) on 2 July 2025, published in the Resmî Gazete on 9 July 2025 (Issue 32951) and entering into force immediately. The law is Türkiye's first comprehensive climate statute, establishing the legal framework for a national Emissions Trading System (ETS) — pilot phase from 2026, full implementation from 2028 — and creating the Carbon Market Board (Karbon Piyasası Kurulu) to govern allowance allocation and market operations. The ETS is designed for EU Carbon Border Adjustment Mechanism (CBAM) compatibility, materially affecting Türkiye's steel, cement, aluminium, and fertilizer export sectors, for which the EU is the primary market.

On 26 June 2025 President Bola Ahmed Tinubu signed four acts constituting Nigeria's most comprehensive fiscal overhaul in decades: the Nigeria Tax Act 2025 (NTA), Nigeria Tax Administration Act 2025 (NTAA), Nigeria Revenue Service (Establishment) Act 2025, and Joint Revenue Board (Establishment) Act 2025. The NTA consolidates and repeals six core statutes — CITA, PITA, PPTA, VAT Act, CGT Act, and Stamp Duties Act — into a single unified code effective 1 January 2026, while the NTAA standardises assessment, filing, and enforcement procedures across all federal taxes. The two establishment acts restructure the Federal Inland Revenue Service (FIRS) into the Nigeria Revenue Service (NRS) with a broadened mandate and create an empowered Joint Revenue Board to coordinate federal-state fiscal relations.

On 11 April 2025 President Javier Milei signed Decreto de Necesidad y Urgencia 269/2025, published in the Boletín Oficial on 14 April 2025 (edición Nº 35.647). The decree repealed Decreto 28/2023, formally lifting the cepo cambiario — the foreign-exchange restrictions that had been in continuous operation in some form since November 2011. Operative provisions include elimination of the 80/20 export-proceeds-channelling mandate, removal of individual USD purchase and wire-transfer caps, permission for companies to repatriate post-1-January-2025 dividend profits, and replacement of the daily crawling-peg with a band float within a $1,000–$1,400 ARS/USD corridor with BCRA floor/ceiling intervention rules. The measure was coordinated with the IMF Extended Fund Facility (USD 20bn total; USD 15bn 2025 free-availability tranche) approved 11 April 2025, and operationalises the currency-stability guarantee embedded in the RIGI large- investment regime (Law 27.742, July 2024).

Japan's National Diet enacted the Cyber Response Capability Enhancement Act (重要電子計算機に対する不正な行為による被害の防止に関する法律, Law No. 42 of 2025) on 16 May 2025, together with companion arrangement legislation. Commonly known as the Active Cyber Defense (ACD) Law, the statute authorises (i) government monitoring of foreign-origin internet traffic transiting designated Japanese communication infrastructure for national-security threat indicators, (ii) pre-emptive access and neutralisation operations against attacker infrastructure abroad by the National Police Agency and the Self-Defense Forces under unified command, and (iii) mandatory cyber-incident reporting and government cooperation duties on critical-infrastructure operators. Implementation is phased through November 2027, with the NISC reorganised into the National Cybersecurity Office (NCO) under the Cabinet Secretariat from July 2025.

The Minerals Regulation Commission Act, No. 14 of 2024 repeals and replaces Zambia's 2015 Mines and Minerals Development Act in its entirety, establishing a new autonomous Minerals Regulation Commission (MRC) as the country's central mining-sector regulator together with a standalone Mining Appeals Tribunal. The Act restructures licensing, royalty administration, monitoring and enforcement, and creates a dedicated dispute-resolution architecture separating regulatory and adjudicatory functions. Assented to on 20 December 2024 and gazetted on 26 December 2024, the Act took effect on 13 June 2025 pursuant to the Minerals Regulation Commission Act, 2024 (Commencement) Order, 2025 (SI 42 of 2025) signed by the Minister of Mines and Minerals Development on 3 June 2025.

The European Union's Artificial Intelligence Act, Regulation (EU) 2024/1689, was published in the Official Journal on 12 July 2024 and entered into force on 1 August 2024. It establishes the world's first horizontal, risk-tiered legal framework for the development, market placement, and use of AI systems — covering prohibited practices, high-risk systems, general-purpose AI models, and minimal-risk applications — with extraterritorial reach over any provider placing an AI system on the EU market or whose output is used in the EU. Penalties reach up to EUR 35 million or 7% of global annual turnover. Application is staged: prohibitions from 2 February 2025, GPAI and governance from 2 August 2025, the bulk of high-risk obligations from 2 August 2026, and product-safety-embedded high-risk systems from 2 August 2027.

On 3 April 2024 the European Commission opened two simultaneous FSR Phase II in-depth investigations — the second and third ever under the Foreign Subsidies Regulation (Regulation 2022/2560) — concerning a Romanian public-procurement procedure for the design, construction and operation of a 454.97 MW EU-co-funded photovoltaic park (Rovinari Est). The first investigation targeted the ENEVO Group consortium including LONGi Solar Technologie GmbH (German subsidiary wholly owned by HK-listed LONGi Green Energy Technology Co., Ltd.); the second targeted Shanghai Electric UK Co. Ltd. and Shanghai Electric Hong Kong International Engineering Co., Ltd. (Chinese SOE). Both respondents withdrew from the procurement procedure after the Commission's opening; the Commission subsequently closed both investigations. This was the first FSR Phase II enforcement action in the renewable-energy / solar-PV sector and the first targeting a private Chinese-listed company's EU subsidiary.

Regulation (EU) 2023/956 of the European Parliament and of the Council, published in OJ L 130 on 16 May 2023 and entering into force on 17 May 2023, establishes the EU Carbon Border Adjustment Mechanism (CBAM) — the Union's primary instrument for preventing carbon leakage at the external border. The regulation applies an equivalent carbon price to embedded greenhouse gas emissions in imports of six sector groups (iron and steel, aluminium, cement, fertilizers, electricity, and hydrogen) from non-EU/EEA/Swiss counterparts, complementing the EU Emissions Trading System's domestic coverage. A transitional reporting-only phase operated from 1 October 2023 through 31 December 2025; the definitive certificate-purchase-and-surrender regime entered full application from 1 January 2026.

Regulation (EU) 2022/2065 on a Single Market For Digital Services (Digital Services Act, DSA) was adopted by the European Parliament and Council on 19 October 2022, published in OJ L 277 on 27 October 2022, entered into force on 16 November 2022, and applied in full from 17 February 2024 (with VLOP/VLOSE obligations applying from 25 August 2023 following the Commission's initial designation letters of February 2023). The DSA establishes a graduated intermediary-liability and platform-safety framework covering all online intermediaries serving EU users, with the heaviest obligations falling on designated Very Large Online Platforms (VLOPs, ≥45m monthly active EU users) and Very Large Online Search Engines (VLOSEs): systemic-risk assessments, annual independent audits, vetted-researcher data access, recommender-system transparency, online-advertising transparency, and crisis-response cooperation mechanisms under Commission coordination. The European Commission holds exclusive enforcement authority over VLOPs and VLOSEs, with fines up to 6% of global turnover. The DSA is the structural twin-pillar to the Digital Markets Act (Reg (EU) 2022/1925): the DMA governs ex-ante competition obligations on designated gatekeepers; the DSA governs ex-post intermediary-liability, content-moderation, and platform-safety obligations across all online intermediaries.

Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector (Digital Markets Act, DMA) was published in OJ L 265 on 12 October 2022, entered into force on 1 November 2022, and applied for the most part from 2 May 2023. The DMA establishes an ex-ante competition framework imposing binding obligations and prohibitions on designated "gatekeepers" operating Core Platform Services (CPS) in the EU — covering search engines, social-networking services, video-sharing platforms, number-independent interpersonal communications, operating systems, web browsers, virtual assistants, cloud computing, online intermediation services, and online advertising. The European Commission designated six gatekeepers on 6 September 2023 (Alphabet, Amazon, Apple, ByteDance, Meta, Microsoft); full compliance with all obligations was required by 7 March 2024. Subsequent designations added Booking.com (May 2024) and Apple iPadOS (April 2024). The DMA functions as the EU's structural anchor for ex-ante digital competition regulation, closing the enforcement gap left by ex-post competition law (Articles 101–102 TFEU) where market-tipping dynamics make remedies ineffective after the fact.

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 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.

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.

Japan's Foreign Exchange and Foreign Trade Act (FEFTA, Act No. 228 of 1 December 1949; 外国為替及び外国貿易法) is the foundational umbrella statute governing the entire modern Japanese economic-statecraft toolkit. Originally a restrictive positive-list regime for foreign-exchange transactions, FEFTA was fundamentally liberalised by the 1980 revision (positive-list to negative-list shift) and again overhauled in 1998 to establish the modern regulatory architecture. Three principal enforcement arms operate under FEFTA: (i) security export controls administered by METI via the Export Trade Control Order and the Foreign Exchange Order (covering the Wassenaar Arrangement, Australia Group, MTCR, NSG, and CWC controlled-items lists plus Japan-specific catch-all controls); (ii) inward FDI screening administered jointly by the Ministry of Finance and sector ministries (prior notification and pre-notification regime, substantially expanded 2019–2020 with Core Business Sectors covering semiconductors, critical minerals, advanced materials, cloud computing, and aerospace added 2021); and (iii) autonomous economic sanctions (asset- freeze and payment-restriction designations against Russia, Iran, DPRK, Myanmar, Belarus, and others via Cabinet Orders made under FEFTA authority). Structurally peer-foundational to the US Trade Expansion Act 1962, US Trade Act 1974, UK SAMLA 2018, CN Export Control Law 2020, and CN Anti-Foreign Sanctions Law 2021 as the G7+CN foundational economic- statecraft statute cluster.