Industrial Policy & Trade Monitor· 2663 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.

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 12 March 2026 Senegal's Primature held a press conference releasing mid-term findings of the National Commission for the Re-evaluation and Renegotiation of Petroleum, Gas, and Mining Contracts, created in August 2024 under Prime Minister Ousmane Sonko's reform programme. The Commission identified a 1,075.9 billion FCFA shortfall in the mining sector — concentrated in unpaid taxes/royalties and unauthorised tax exemptions at ICS (Industries Chimiques du Sénégal) — and announced the termination of four offshore oil-exploration blocks (Djifer Offshore, Kayar Offshore, Saint-Louis Offshore, Rufisque Offshore). Renegotiation of the Greater Tortue Ahmeyim (GTA) gas project, operated by BP with Kosmos Energy and Woodside as partners on the Senegal-Mauritania maritime border, is under active examination; the Primature projects 900 bn FCFA in incremental fiscal revenue 2026-2040 from the contract revision programme. This is Senegal's first major instance of retroactive resource-contract review under the Sonko-Faye government and establishes the legal-political baseline for subsequent contract renegotiations across the 27 mining contracts and remaining hydrocarbon licences under Commission review.

President Trump signed Executive Order "Ending Certain Tariff Actions" on 20 February 2026 (Federal Register doc 2026-03832, published 25 February 2026), terminating the additional ad-valorem duties imposed under nine prior IEEPA-based executive orders. The order followed within hours of the US Supreme Court's 6-3 decision the same day in Learning Resources, Inc. v. Trump, 607 U.S. ___ (2026), holding that the International Emergency Economic Powers Act does not authorize the President to impose tariffs and vacating the Trump 2.0 IEEPA tariff regime. The EO directs CBP to cease collection "as soon as practicable"; CSMS guidance set the collection-end date at 12:00 a.m. eastern on 24 February 2026. The order explicitly preserves all underlying national-emergency declarations and all non-IEEPA trade actions — Section 232 of the Trade Expansion Act, Section 301 of the Trade Act, Section 122 of the Trade Act, and Section 201 — so the Section 232 cascade and the paired Section 122 10% temporary surcharge (effective 24 Feb 2026) remain in force. This is the first SCOTUS-driven repeal of a presidential tariff regime in the modern era and recalibrates the entire post-2024 US tariff architecture by removing IEEPA as a legal pillar.

On 13 February 2026 President Bola Ahmed Tinubu signed Executive Order No. 9 of 2026 directing all Production Sharing Contract operators and contractors to remit Royalty Oil, Tax Oil, Profit Oil, and Profit Gas directly to the Federation Account, bypassing prior NNPC Limited intermediated collection. The order simultaneously eliminates NNPC Limited's 30% management fee on profit oil/gas, suspends the 30% Frontier Exploration Fund deduction, and redirects Gas Flare Penalty proceeds to the Federation Account — materially walking back the fiscal architecture established under Petroleum Industry Act 2021 §§ 9 and 53. An Implementation Committee chaired by the Minister of Finance was established to operationalise the order and resolve disputes.

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).

Germany's first cross-sector federal statute establishing minimum requirements for the physical protection and resilience of critical infrastructure operators (KRITIS) — sectors covered include energy, transport, water, food, ICT, financial services, health, and federal government infrastructure. Transposes EU Directive 2022/2557 (CER Directive on the resilience of critical entities). Identifies operators of critical facilities with Europe-wide significance, mandates national risk analyses for critical services, requires operator risk-management measures and creates a federal incident-reporting regime. Passed by the Bundestag on 29 January 2026, confirmed by the Bundesrat on 6 March 2026, published in BGBl. 2026 I Nr. 66 on 16 March 2026, in force from 17 March 2026.

Regulation (EU) 2026/261 of the European Parliament and of the Council (adopted 26 January 2026, in force 3 February 2026) sets a legally binding stepwise ban on imports of Russian-origin natural gas — both liquefied (LNG) and pipeline. Russian LNG under short-term contracts signed before 17 June 2025 is prohibited from 25 April 2026; long-term LNG contracts from 1 January 2027. Russian pipeline gas under short-term contracts is prohibited from 17 June 2026; long-term pipeline gas from 30 September 2027 (latest 1 November 2027 if EU storage targets remain on track). The regulation operates outside the Russia-sanctions architecture (Article 215 TFEU) as a REPowerEU internal-market instrument, with narrow operational-amendment carve- outs and no provision for volume increases.

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.