Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

President Trump signed an Executive Order on June 3, 2026 restructuring the entire US customs-entry compliance architecture for global importers. Key provisions impose heightened bonding minimums and domestic-asset requirements for foreign importers of record (IORs), require CAATSA-compliance and supply-chain-disclosure certifications, restrict foreign IORs to formal entry only (creating a de facto US-IOR monopoly on informal entry), establish a "good standing" requirement for IOR eligibility, and sharply curtail CBP's mitigation authority while setting enhanced penalty floors. DHS/CBP is directed to implement penalty-floor, export-documentation, and disposal provisions within 90 days (~September 2026) and the IOR structural reforms within 180 days (~November 2026). The EO is structurally distinct from tariff-rate instruments (Section 232 Proclamations 11021/11032), trade-remedy channels (USTR Section 301), statutory forced-labor enforcement (UFLPA), and targeted-sanctions channels (BIS/OFAC) — it reshapes the foundational compliance architecture through which all goods enter the US market.

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.

Arrêté ministériel n° 00964/CAB.MIN/MINES/01/2025, signed 19 December 2025 by DRC Mines Minister Louis Watum Kabamba, suspends with immediate effect all activities of entities (notably comptoirs d'achat / buying counters, treatment units and similar structures) involved in the purchase, processing, transformation and commercialisation of copper and cobalt minerals sourced from artisanal exploitation across the country. Industrial, legally established mining operators are excluded. The order requires affected entities to submit compliance documentation within ten days, establishes an ad hoc commission to verify administrative, legal, technical and traceability conformity (15-day review window), and obliges operators to demonstrate the lawful origin of their supplies in line with OECD due-diligence guidance. Framed as a "conservatory" measure to restore order in the cupro-cobaltifère value chain and curb illicit exports.

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.

In the early hours of 11 December 2025 the Council of the EU and the European Parliament reached provisional political agreement in trilogue on the "EU Pharma Package" — the revised pharmaceutical Regulation (COM 2023/0131) and Directive (COM 2023/0132) — the most significant overhaul of EU pharmaceutical legislation in over two decades. The package replaces Directive 2001/83/EC (Community Code on medicinal products for human use) and Regulation (EC) 726/2004 (the EMA Regulation), and consolidates the orphan-medicine (Regulation 141/2000) and pediatric-medicine regulations into a single framework. Headline provisions: (i) a new "8+1(+1)(+1)" IP-incentive architecture — 8 years of regulatory data protection plus 1 year of market protection, with up to two additional 12-month extensions for products addressing unmet medical need or new active substances meeting comparative-trial conditions, capped at 11 years total; (ii) an EU-wide list of critical medicines under enhanced governance via the Medicines Shortages Steering Group (MSSG) and an EMA "list of critical shortages in the EU"; (iii) mandatory shortage-prevention plans on marketing-authorisation holders for prescription medicines and Commission-designated products; (iv) modernisation of clinical-trial requirements, environmental-risk assessment, antimicrobial stewardship, and a transferable-exclusivity-voucher (TEV) regime to incentivise novel antibiotic R&D. The COREPER I committee endorsed the compromise text on 6 March 2026 and final adoption by Parliament and Council is expected during summer 2026, with the regulatory framework becoming applicable in 2028.

On 6 November 2025, the US Department of the Interior (DOI) and the US Geological Survey (USGS) released the final 2025 List of Critical Minerals under the Energy Act of 2020 (30 U.S.C. § 1606), expanding the designation from 50 to 60 minerals. The final list adds 10 newly designated commodities — boron, copper, lead, metallurgical coal, phosphate, potash, rhenium, silicon, silver, and uranium — based on updated supply-chain disruption modelling, public comment, and interagency recommendations. The list constitutes the foundational statutory anchor for downstream US critical-minerals policy instruments including DPA Title III awards, DOE LPO Title 17 loan eligibility, IRA Section 45X Advanced Manufacturing Production Credit eligibility, Section 30D FEOC determinations, BIS export-control predicate assessments, Section 232 trade-investigation predicates, and CFIUS critical-technology triggers under 31 CFR § 800.215.

BIS (acting through its Office of Information and Communications Technology and Services, OICTS) published a final rule under Executive Order 13873's ICTS authority prohibiting certain connected-vehicle (CV) transactions involving hardware and software designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction of the People's Republic of China or the Russian Federation. The rule reaches the Vehicle Connectivity System (VCS — hardware/software enabling external RF connectivity above 450 MHz) and the Automated Driving System (ADS) software stack. Effective 17 March 2025, with phased prohibitions: import/sale of CVs incorporating covered software prohibited from model year 2027; import of covered VCS hardware prohibited from model year 2030 (or 1 January 2029 for hardware not associated with a model year). Importers and connected-vehicle manufacturers must file annual Declarations of Conformity.

The Cook Islands government promulgated the Seabed Minerals (Minerals Harvesting and Other Mining) Regulations 2024 (Serial 2024/11), entering into force 1 October 2024, as the first statutory framework enabling commercial-scale polymetallic-nodule harvesting in the Cook Islands' 1.96 million km² EEZ — one of the world's largest documented manganese-nodule provinces estimated at ~6.7 billion metric tonnes. The Regulations were issued by the SBMA under the Seabed Minerals Act 2009 and establish the licensing pathway, environmental-assessment standards, royalty-and-benefit-sharing framework, production-licence application criteria, and operator financial-assurance requirements for the commercial harvesting tier. The government has stated that only exploration activities are currently permitted and that harvesting licences will not be granted until a science-based environmental decision has been made; the Regulations nonetheless create the legal architecture that would activate commercial extraction, structurally peer to Norway's June 2024 Arctic seabed-mining opening and ahead of the stalled ISA Mining Code negotiations.

The Department of Commerce published a final rule redesignating the regulations implementing Executive Order 13873 (Securing the Information and Communications Technology and Services Supply Chain) from 15 CFR subtitle A, part 7 (Office of the Secretary of Commerce) to 15 CFR subtitle B, chapter VII, part 791, under the Bureau of Industry and Security (BIS). The redesignation reflects the formal transfer of ICTS-transaction review authority from the Secretary of Commerce to BIS's new Office of Information and Communications Technology and Services (OICTS). The rule is non-substantive — it relocates the existing regulatory text without altering the scope of covered ICTS transactions, the foreign-adversary list, the review procedures, or any substantive obligations on parties. Effective on publication (18 July 2024) without notice and comment because it is an internal agency reorganization.

Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), replaces the 2009 Ecodesign Directive with a cross-cutting product-sustainability framework covering nearly all physical goods placed on the EU single market. It empowers the Commission to adopt binding delegated acts setting ecodesign requirements (durability, reparability, recyclability, recycled content, chemical restrictions, energy and resource efficiency) by product category, establishes a mandatory Digital Product Passport (DPP) for supply-chain traceability, and bans the destruction of unsold consumer products. The regulation entered into force on 18 July 2024; the Commission's first ESPR and Energy Labelling Working Plan (2025–2030, COM(2025) 187) was adopted in April 2025, prioritising textiles, furniture, tyres, electronics, and iron/steel/aluminium.

The Central African Republic enacted a comprehensive new Mining Code (Law No. 24-008) in May 2024, replacing the prior framework to govern all prospecting, exploration, exploitation, processing, and marketing of mineral deposits. The code creates two state enterprises: GEMINCA (Gemmes et Minéraux de Centrafrique), mandated as the state-designated purchaser of precious and semi-precious minerals — introducing a state monopsony channel for diamond and gold purchasing — and SONADERM (Société Nationale de Développement des Ressources Minérales), charged with geological survey and mineral-domain promotion. Mandatory EITI, Kimberley Process, and ICGLR compliance is imposed on all mining title holders, forecloses informal-sector operators, and tightens supply-chain due-diligence requirements for downstream importers. A companion formalisation framework licences artisanal and small-scale mining through cooperatives and purchasing-office structures, and a dedicated mining fund distinct from Treasury accounts is established to channel sector revenues.

Belgium's Loi du 29 février 2024 (published in the Moniteur Belge on 27 May 2024, entering into force 1 June 2026) establishes the first comprehensive federal authorisation and traceability regime for pharmaceutical raw materials used by pharmacists in extemporaneous and magistral preparations. Manufacturers, importers, and distributors of covered materials must obtain AFMPS authorisation and comply with Good Manufacturing Practice and Good Distribution Practice standards; pharmacists may only source materials from authorised actors. The statute was enacted during Belgium's EU Council Presidency (H1 2024) and directly parallels the EU Critical Medicines Alliance architecture launched in Leuven on 24 April 2024, positioning Belgium as the first EU member state to operationalise a national supply-chain control layer for pharmaceutical compounding raw materials ahead of the forthcoming EU Critical Medicines Act.

A joint advisory issued January 26, 2024 by six US agencies (USTR, State, Treasury, Commerce, DHS, and Labor) updating businesses on supply-chain risks associated with Burma's post-coup military regime (SAC). The advisory warns of reputational, economic, and legal exposure for entities operating in or sourcing from Burma and specifically flags heightened due-diligence requirements for metal importers, the SAC's opaque network of corporate affiliates in Thailand, Singapore, India, and the UAE that complicate traceability, and cross-border reporting gaps for goods and funds transfers. Targeted sectors include rare earths (dysprosium, terbium), base metals and gold mining, timber, aviation services and jet fuel, computer chips and ICT equipment, and small arms components.

Regulation (EU) 2023/1542 establishes a comprehensive EU statutory framework for all battery categories (portable, SLI, LMT, EV, industrial), imposing supply-chain due-diligence obligations for cobalt, lithium, nickel, and natural graphite; mandatory recycled-content thresholds; carbon-footprint declarations; a digital battery passport; and ambitious collection and recycling-efficiency targets, with rolling application dates running from February 2024 through August 2036. It repeals Battery Directive 2006/66/EC and applies to every economic operator placing batteries on the EU market, binding every EV, consumer-electronics, and stationary-storage supply chain that relies on DRC cobalt, Australian/Chilean lithium, Indonesian/Philippine nickel, and Chinese/Mozambican graphite.

Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9; "Bill S-211") received Royal Assent on 11 May 2023 and entered into force on 1 January 2024. It imposes a binding annual supply-chain disclosure obligation on government institutions and in-scope private-sector entities (any two of: ≥CAD 20m assets, ≥CAD 40m revenue, ≥250 employees) requiring a public report by 31 May each year detailing steps taken to prevent and reduce the risk of forced or child labour in their supply chains. The Act also amends the Canadian Customs Tariff (Schedule 9898.00.00) to extend the existing import prohibition on goods produced with forced labour to also cover goods produced with child labour, enforced at the border by the Canada Border Services Agency (CBSA). Criminal penalties of up to CAD 250,000 apply for non-compliance, false reporting, or obstruction.

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.

Loi n° 2014-138, adopted by the Assemblée nationale and promulgated by President Alassane Ouattara on 24 March 2014, is the foundational mining-rights statute governing all mineral prospecting, research, and exploitation in Côte d'Ivoire. Its 197 articles across 16 titles repeal the prior Loi n° 95-553 (1995 Code Minier) and establish the modern permit regime, a 10% state free-carry in all industrial mining projects via SODEMI, and the royalty + ad valorem fiscal architecture that underpins every subsequent mining-convention and fiscal-law amendment. As West Africa's second-largest gold producer (approx. 45 t/yr) with growing bauxite and manganese exploration, CI's mining-code architecture is a material determinant of supply-chain access for Western and Chinese industrial consumers of these commodities.