China is a member of the World Trade Organization (WTO). It participates in WTO plurilateral agreements, including the Trade Facilitation Agreement and the Government Procurement Agreement. China is a full party to the Trade Facilitation Agreement (TFA), which entered into force on 22 February 2021. China is currently negotiating its formal membership in the Government Procurement Agreement. Furthermore, China is a signatory to the updated Information Technology Agreement (ITA), which eliminates tariffs on a range of information technology products.

As of 1 January 2025, China has signed 23 free trade agreements with 30 countries and regions. The following are some of the major ones.

• Asia – ASEAN (Thailand, Vietnam, Indonesia, Malaysia, the Philippines, Myanmar, Laos, Singapore, Cambodia and Brunei); South Korea (China–South Korea Free Trade Agreement, effective in 2015); Japan (China–Japan Free Trade Agreement, currently under negotiation); and APEC members (economic cooperation agreements between China and several Asia-Pacific countries and regions).
• Europe – Switzerland (China–Switzerland Free Trade Agreement, effective in 2014); Iceland (China–Iceland Free Trade Agreement, effective in 2014).
• Latin America – Chile (China–Chile Free Trade Agreement, effective in 2006); Peru (China–Peru Free Trade Agreement, effective in 2010); and Brazil (extensive economic co-operation under multiple frameworks).
• Africa – South Africa (close economic co-operation in mining and agriculture); and other African countries (regional trade agreements such as AfCFTA).
• Oceania – Australia (China–Australia Free Trade Agreement, effective in 2015); and New Zealand (China–New Zealand Free Trade Agreement, effective in 2008).
• Middle East – UAE (China–UAE Free Trade Agreement under negotiation).
• Others – Pakistan and other countries also have free trade agreements with China.

China has enjoyed Generalised System of Preferences (GSP) treatment from most countries since 1978. However, 32 countries including EU member states and the United Kingdom terminated GSP benefits for China on 1 December 2021. Concurrently, China’s General Administration of Customs ceased issuing GSP certificates of origin for exports to these regions. Currently, only Norway, Australia and New Zealand maintain GSP treatment for China.

During the FTA negotiation phase, China actively co-operated with a number of countries and regions to promote trade liberalisation and economic integration. The following are some key developments in the negotiations.

• China–Switzerland Free Trade Agreement Upgrade Negotiations – in July 2024, China and Switzerland will commence negotiations to upgrade their Free Trade Agreement. The first round of negotiations took place in Beijing from 18 to 20 March 2025. The second round was held in Geneva, Switzerland, from 7 to 10 July 2025.
• China–ASEAN FTA 3.0 Negotiations – on May 20, the China-ASEAN Special Meeting of Economic and Trade Ministers was held online. Economic and trade ministers from both sides jointly announced the full completion of negotiations for the China-ASEAN Free Trade Area 3.0.
• China-US “Phase Two” Trade Agreement – on 10 and 11 May 2025, the Chinese and US trade chiefs, Vice Premier Lifeng He, and their US counterparts, US Treasury Secretary Jeffrey Bessant and Trade Representative Greer, held high-level trade talks in Geneva, Switzerland. The two sides engaged in candid, in-depth, and constructive discussions on implementing the important consensus reached during the January 17 call between the Chinese and US presidents, reaching a series of important consensuses and achieving substantial progress.

In 2025, China has implemented multiple significant measures in trade policy-related legislation, enforcement and compliance, including the following.

• Strengthening trade policy compliance – the General Office of the State Council issued the “Opinions of the General Office of the State Council on Further Strengthening Trade Policy Compliance”, emphasising the importance of compliance work and putting forward specific requirements and tasks.
• Improving the legal framework – revision of the Foreign Trade Law. The draft revision elevates reform measures such as the negative list management system for cross-border service trade to legal status, ensuring the effective implementation of these reforms.
• Strengthening intellectual property protection – the state strengthens intellectual property protection related to foreign trade and improves the intellectual property compliance and risk-response capabilities of foreign trade operators.
• Establishing a trade adjustment assistance system – to stabilise industrial chains and supply chains.
• Enhancing the service network of professional service agencies – encourage professional service agencies to improve their service networks and provide high-quality professional services to foreign trade operators.
• Establishing a diversified dispute resolution mechanism for foreign trade – including improvements.

In 2025, China’s trade regulatory activities will be affected by a series of major policies. The following are some key trade regulatory activities.

• Export controls across the entire rare earth industry chain – China’s Ministry of Commerce issued seven notices to comprehensively strengthen export controls across the entire rare earth industry chain. This marks China’s first implementation of extraterritorial jurisdiction rules established under Article 49 of the Export Control Regulations for Dual-Use Items, which falls under the Export Control Law.
• Export controls on lithium battery-related industries – China is continuously strengthening export controls on lithium battery-related industries to safeguard national security and core industrial interests.
• Export controls on superhard materials – China is also strengthening its export controls on superhard materials (synthetic diamonds) to safeguard national security and core industrial interests.
• Unreliable entity list – China has added 14 foreign entities, including a counter-drone technology company, to its unreliable entity list to safeguard national security.

A major trade policy dispute resolution case in 2025 was the China–EU WTO Dispute Case, a trade dispute between China and the EU within the World Trade Organization framework concerning standard essential patent (SEP) anti-suit injunctions, Case No DS611.

The significant pending changes, hot topics and issues likely to emerge in China’s trade policy over the next 12 months include the following.

• The evolution of US–China trade relations – the bilateral trade relationship has shifted from a relatively stable economic complementary relationship to strategic confrontation under high tariff barriers. This transformation represents a continuation and escalation of the trade war that began in 2018.
• Shifts in the global trade landscape – as the US-China trade relationship evolves, the global trade landscape may be affected by the emergence of new political and economic alliances, increased geopolitical tensions, and significant industrial landscape shifts.
• Digital transformation – may propel industries toward higher levels, stimulate demand for new goods, and establish trade hubs centred on digital and eco-friendly products.
• Policy uncertainty – heightened policy uncertainty could worsen the global economic outlook, and businesses are delaying or scaling back key investment decisions.

China Customs is the national authority responsible for overseeing the entry and exit of goods. In accordance with laws and administrative regulations, China Customs supervises the entry and exit of means of transport, goods, luggage, postal items and other articles; collects customs duties and other taxes and fees; investigates and suppresses smuggling; compiles China Customs statistics; and handles other China Customs affairs.

The General Administration of Customs of China is a ministerial-level agency directly under the State Council. It currently has 21 internal departments, 13 directly affiliated enterprises and institutions in Beijing, two social organisations and 45 units directly under the Chinese Customs. The Central Commission for Discipline Inspection has stationed discipline inspection groups at the General Administration of Customs of China.

China currently has no legal instrument similar to the Trade Barriers Regulation of the European Union or Section 301 of the US Trade Act of 1974.

In 2025, China Customs implemented a series of important legal and regulatory activities to optimise the access and regulatory model for imported goods and promote the development of foreign trade. The General Administration of Customs issued the “Regulations on the Administration of Declaration of Import and Export Goods of China Customs” to standardise the declaration and inspection of imported and exported goods. In addition, it will launch a reform of the “two-step declaration” customs clearance model to optimise the pilot programme and promote trade facilitation.

In accordance with the China Export Control Law and other relevant laws and regulations, on 9 October 2025, the Ministry of Commerce, together with the General Administration of Customs, issued an announcement on the implementation of export control measures on five types of medium and heavy rare earths including superhard materials, rare earth equipment and raw/auxiliary materials and holmium, lithium batteries and artificial graphite negative electrode materials. These measures were officially implemented on 8 November 2025.

The General Administration of Customs also issued an announcement on the implementation of mutual recognition of Authorised Economic Operators (AEO) between China and Mongolia, which officially took effect on 1 June 2025. This will help strengthen the management of special customs supervision areas, bonded supervision areas and off-zone processing trade.

In addition, the General Administration of Customs issued an announcement on adjusting the relevant management measures for customs special supervision areas, bonded supervision areas, and processing trade outside the area, involving the management of commodities such as tariff quota management and trade relief measures.

In the future, China customs and import measures may undergo significant changes in the following areas.

• Enhanced export controls – China will comprehensively strengthen export controls on the entire rare earth industry chain, lithium battery-related industrial chains and superhard materials-related items.
• Further advancement in foreign trade – China’s foreign trade enterprises continue to innovate and develop, maintaining a positive momentum characterised by improved quality and stable volume. China is building a new development paradigm centred on domestic circulation while promoting mutual reinforcement between domestic and international circulation. China will persist in its proactive opening-up strategy, share the advantages of its massive market demand with the world, and strive to remain a solid and reliable component within the global division of labour system.
• Cross-border compliance insights – the significant upgrade of China’s export control measures profoundly impacts the global supply chain landscape.

China’s sanctions regime comprises laws, administrative regulations and departmental rules including the China Anti-Foreign Sanctions Law, the China National Security Law, the China Cybersecurity Law, the China Anti-Terrorism Law, the China Personal Information Protection Law, the China Foreign Trade Law, the China Foreign Relations Law, the China Anti-Money Laundering Law, the Administrative Penalty Law, the Criminal Law, the Measures for Blocking the Improper Extraterritorial Application of Foreign Laws and Measures, the Provisions on the Unreliable Entity List and the Provisions on the Implementation of the China Anti-Foreign Sanctions Law.

China’s Ministry of Commerce and Ministry of Foreign Affairs are the primary regulatory bodies for sanctions in China. The Ministry of Commerce is responsible for import and export controls and trade-related sanctions. The Ministry of Foreign Affairs is responsible for the country’s foreign policy, including sanctions against foreign entities and individuals. The State Council’s Foreign Affairs, Commerce, Development and Reform Commission and Justice Administration departments, in accordance with their respective responsibilities and tasks, are responsible for the co-ordination mechanism for countering foreign sanctions. Relevant departments of the State Council will strengthen co-ordination and information sharing in the identification and implementation of countermeasures.

In addition to the Ministry of Foreign Affairs and the Ministry of Commerce of the State Council of China, the government agencies responsible for managing and implementing the sanctions regime include relevant departments such as the National Immigration Administration, public security, finance, natural resources, transportation, customs, market supervision, financial management and intellectual property, as well as relevant departments of the State Council such as education, science and technology, judicial administration, ecological environment, commerce, culture and tourism, health, and sports administration.

Chinese citizens, legal persons, and other organisations, as well as those engaging in activities within China, must comply with Chinese sanctions laws, regulations and other provisions. Foreign citizens, legal persons and other organisations engaging in activities outside China, as well as those that violate relevant laws, may also be held legally liable.

China’s laws and regulations, such as the China Anti-Foreign Sanctions Law and the Regulations on the Unreliable Entity List, provide that relevant departments of the State Council may designate individuals and organisations that directly or indirectly participate in the formulation, decision-making or implementation of discriminatory restrictive measures as being included in the counter-measures list. Furthermore, relevant departments of the State Council may also decide to take counter-measures against the following individuals and organisations:

• spouses and immediate family members of individuals listed on the counter-measures list;
• senior management personnel or actual controllers of organisations listed on the counter-measures list;
• organisations where individuals listed on the counter-measures list serve as senior management personnel; and
• organisations actually controlled by, or co-founded or operated by, individuals and organisations listed on the counter-measures list.

Depending on the circumstances, these measures may include one or more of the following:

• refusal to issue a visa, denial of entry, cancellation of a visa, or deportation;
• seizure, detention or freezing of movable, immovable and other property within China;
• prohibition or restriction of organisations or individuals within China from engaging in transactions, co-operation, or other activities with them; and
• other necessary measures.

China has not yet released a list of sanctions or embargoes targeting specific countries and regions.

China currently does not maintain any other types of sanctions (non-embargo, full embargo, non-list-based).

China has not imposed or threatened to impose sanctions on transactions unrelated to China (secondary sanctions).

According to the relevant provisions of the China Anti-Foreign Sanctions Law and other laws, regulations and rules, violations of sanctions-related laws and regulations may result in being placed on the countermeasures list and subject to countermeasures (including the denial of visas, entry denial, visa cancellation, or deportation; the seizure, detention, and freezing of movable, immovable, and other property within Chinese territory; the prohibition or restriction of organisations or individuals within Chinese territory from engaging in relevant transactions or cooperation with them; and other necessary measures).

Violators may also be placed on the Unreliable Entity List and be subject to disciplinary measures (such as restrictions or prohibitions on import and export activities related to China; restrictions or prohibitions on investment within China; restrictions or prohibitions on the entry of related personnel and transportation vehicles; restrictions or cancellations of related personnel’s work permits, stay or residence permits within China; and fines commensurate with the severity of the circumstances; and other necessary measures). Violators may face civil lawsuits from relevant individuals or organisations.

Violations of Chinese criminal law may also result in criminal prosecution and other consequences and risks. Furthermore, there is the potential for reputational damage, loss of business opportunities and investigations, prosecutions, and trials by other Chinese and other state agencies and organisations.

Pursuant to the Provisions on the Unreliable Entity List, where Chinese enterprises, other organisations or individuals have a genuine need to conduct transactions with foreign entities restricted or prohibited from engaging in import-export activities related to China under special circumstances, they shall submit an application to the Office of the Working Mechanism established by the relevant departments of the central state organs. Upon approval, they may engage in corresponding transactions with such foreign entities.

China adheres to an independent and peaceful foreign policy and the Five Principles of Peaceful Coexistence: mutual respect for sovereignty and territorial integrity, mutual non-aggression, non-interference in each other’s internal affairs, equality and mutual benefit, and peaceful coexistence. It upholds the international system with the United Nations at its core and the international order based on international law, develops friendly co-operation with all countries, and promotes the building of a community with a shared future for mankind. China opposes hegemony and power politics, and opposes any country interfering in China’s internal affairs under any pretext or in any way. China opposes foreign containment and suppression, the imposition of discriminatory restrictive measures against Chinese citizens and organisations, and interference in its internal affairs.

According to the relevant provisions of the Rules on Counteracting Unjustified Extraterritorial Application of Foreign Legislation and Other Measures, if Chinese citizens, legal persons or other organisations encounter situations where foreign laws and measures prohibit or restrict their normal economic, trade and related activities with third countries (regions) and their citizens, legal persons or other organisations, they shall truthfully report the relevant situation to the commerce department of the State Council within 30 days.

China has established the Rules on Counteracting Unjustified Extraterritorial Application of Foreign Legislation and Other Measures. These measures apply to situations where the extraterritorial application of foreign laws and measures violates international law and basic norms governing international relations, and improperly prohibit or restrict Chinese citizens, legal persons or other organisations from conducting normal economic, trade and related activities with third countries (regions) and their citizens, legal persons or other organisations.

Key developments in sanctions-related law, regulatory activity, enforcement, litigation or public attention in the past 12 months are as follows.

• The promulgation and implementation of the Regulations on the Implementation of China’s Anti-Foreign Sanctions Law, issued on 24 March 2025, which details the relevant provisions of the Anti-Foreign Sanctions Law, clarifies the scope of application, the specific content of countermeasures, the departments with executive authority and responsibilities, and the relief channels, strengthens inter-departmental co-ordination, and provides a handle for China to deepen the implementation of various countermeasures in the next stage.
• Enhanced export control measures – on 9 October 2025, China’s Ministry of Commerce issued seven important announcements, comprehensively strengthening export controls on the entire rare earth industry chain, lithium battery-related industry chain, and superhard material-related items, and adding 14 foreign entities to the Unreliable Entity List.
• Counter-sanctions enforcement – in 2024, China’s Ministry of Commerce conducted 12 counter-sanctions enforcement actions, adding 118 sanctioned entities to the counter-measures list. In the first two months of 2025, China’s Ministry of Commerce issued four consecutive announcements, adding 23 foreign entities to the Unreliable Entity List.

Further refinement of China’s sanctions-related laws and regulations, coupled with enhanced enforcement efforts, is expected to be a key trend in China’s sanctions landscape over the next 12 months. Additionally, shifts in US-China relations and the ongoing sanctions-counter-sanctions dynamics between the two nations are likely to remain prominent topics and challenges in the coming period.

China’s export control laws and regulations include the Export Control Law of China, the Foreign Trade Law, the National Security Law, the Data Security Law, the Nuclear Safety Law, the Customs Law, the Administrative Licensing Law, the Administrative Penalty Law, the Criminal Law, etc.

The export control departments of the State Council and the Central Military Commission are responsible for export control work in accordance with their respective duties. Other relevant departments of the State Council and the Central Military Commission are responsible for export control-related work in accordance with their respective duties.

China has established a national co-ordination mechanism for export control to oversee major matters related to export control. The national export control administration and relevant departments of the State Council closely co-operate and enhance information sharing. China’s national export control administration, in conjunction with relevant departments, establishes an expert advisory mechanism for export controls to provide consultation on export control matters. It also issues industry-specific export control guidelines as appropriate to guide export operators in establishing and improving internal compliance systems for export controls and standardising their operations. Relevant departments of the people’s governments of provinces, autonomous regions and municipalities directly under the Central Government are responsible for export control-related work in accordance with the provisions of laws and administrative regulations.

China exercises export controls on dual-use items, military products, nuclear products, and other goods, technologies and services related to safeguarding national security and interests and fulfilling international obligations such as non-proliferation. Controlled items include technical data and other related data.

• Dual-use items refer to goods, technologies and services that have both civilian and military applications or contribute to enhancing military potential, particularly those that can be used in the design, development, production or use of weapons of mass destruction and their delivery systems.
• Military products refer to equipment, specialised production equipment, and other related goods, technologies and services used for military purposes.
• Nuclear products refer to nuclear materials, nuclear equipment, non-nuclear materials for reactors, and related technologies and services.
• Export controls involve prohibiting or restricting the transfer of controlled items from within China to foreign countries, as well as the provision of controlled items by Chinese citizens, legal persons, and unincorporated organisations to foreign organisations and individuals.

China’s national export control administration department establishes a control list for importers and end-users who:

• violate end-user or end-use management requirements;
• may endanger national security and interests; or
• use controlled items for terrorist purposes.

The National Export Control Administration Department may take necessary measures against importers and end-users included in the control list, such as prohibiting or restricting transactions in the relevant controlled items and ordering the suspension of exports.

The national export control management department shall, in accordance with the provisions of relevant laws and administrative regulations, based on export control policies and in accordance with prescribed procedures, jointly with relevant departments, formulate and adjust the export control list of controlled items and publish it in a timely manner.

According to China’s Export Control Law, to safeguard national security and interests, or fulfil international obligations such as non-proliferation, China’s national export control administration may, with the approval of the State Council, or the State Council and the Central Military Commission, impose temporary controls on goods, technologies and services not on the export control list and make an announcement. The duration of temporary controls shall not exceed two years. Before the expiration of the temporary control period, an assessment shall be conducted promptly, and based on the assessment results, a decision shall be made to cancel, extend or add the temporarily controlled items to the export control list. China may also prohibit the export of relevant controlled items, or prohibit the export of relevant controlled items to specific destination countries and regions, organisations or individuals.

Individuals and organisations that violate China’s export controls may be subject to fines; orders to suspend operations for rectification, up to and including revocation of their export licences for controlled items; refusal to process export licence applications for a specified period; and prohibitions from engaging in relevant export activities for a specified period or for life. Criminal offences may also result in criminal prosecution.

China implements a licensing system for the export of controlled items. Exporters of controlled items listed on the export control list or temporarily controlled items must apply for a licence from the national export control administration department.

Export control efforts should adhere to the overall national security outlook, uphold international peace, balance security and development, and enhance export control management and services.

The end-user of controlled items shall undertake not to alter the end-use of such items or transfer them to any third party without authorisation from the national export control administration. Should export operators or importers discover any potential change in the end-user or end-use, they shall immediately report such circumstances to the national export control administration in accordance with regulations.

On 9 October 2025, the Ministry of Commerce and the General Administration of Customs of China issued Announcement No 55, No 56, No 57 and No 58 of 2025, announcing the decision to implement export controls on items related to superhard materials, the decision to implement export controls on some rare earth equipment and raw and auxiliary materials, the decision to implement export controls on some medium and heavy rare earth items, and the decision to implement export controls on items related to lithium batteries and artificial graphite negative electrode materials.

In the next 12 months, China will further accelerate the improvement of the modern national export control system, continuously enhance the effectiveness of export control, co-ordinate development and security, and ensure high-quality development with high-level security. Specifically, China will further improve laws and regulations, strengthen item listing, enhance licensing enforcement, strengthen multilateral and bilateral export control dialogues and exchanges, and promote compliance construction to better safeguard China’s national sovereignty, security and development interests.

The Ministry of Commerce of China is the authority governing the imposition of AD/CVD duties and safeguard measures.

China’s Ministry of Commerce, the Customs Tariff Commission of the State Council, Customs and other relevant agencies are responsible for the management and implementation of anti-dumping/countervailing duties and safeguard measures.

Natural persons, legal persons or relevant organisations in or representing domestic industries may submit written applications for investigation to the Ministry of Commerce in accordance with the law.

Domestic enterprises may submit applications, whether temporary or regular, provided they meet legal requirements. Domestic enterprises may apply according to their own needs.

During anti-dumping proceedings, the Ministry of Commerce shall notify the relevant exporting country (region) government before deciding to initiate an investigation. The Ministry of Commerce shall announce the decision to initiate an investigation and notify the applicant, known exporters and importers, the government of the exporting country (region), and other interested organisations and individuals (hereinafter referred to as “stakeholders”). Once the decision to initiate an investigation is announced, the Ministry of Commerce shall provide the text of the application to known exporters and the government of the exporting country (region).

The Ministry of Commerce may use questionnaires, sampling, hearings, on-site inspections and other methods to gather information from stakeholders and conduct investigations. It shall provide stakeholders with an opportunity to present their opinions and arguments. If deemed necessary, it may dispatch personnel to the relevant country (region) to conduct an investigation, except where the relevant country (region) raises objections. During the investigation, interested parties shall truthfully report the situation and provide relevant information. If an interested party fails to truthfully report the situation or provide relevant information, fails to provide necessary information within a reasonable time, or otherwise seriously obstructs the investigation, the Ministry of Commerce may make a ruling based on the facts obtained and the best available information. There are similar participation provisions in anti-subsidy and safeguard procedures.

In China, the relevant procedures for investigating and imposing anti-dumping duties are as follows.

• Domestic industries or natural persons, legal persons or relevant organisations representing domestic industries shall submit written applications for investigation to the Ministry of Commerce.
• 60 days after receiving the application and relevant evidence submitted by the applicant, the Ministry of Commerce shall review whether the application is submitted by or on behalf of the domestic industry, the content of the application and the accompanying evidence, and decide whether to initiate an investigation or not. Before deciding to initiate an investigation, the government of the relevant exporting country (region) shall be notified.
• The Ministry of Commerce will announce the decision to initiate an investigation and notify the applicant, known exporters and importers, the government of the exporting country (region) and other interested organisations and individuals (hereinafter referred to as “interested parties”). Once the decision to initiate an investigation is announced, the Ministry of Commerce shall provide the text of the application to known exporters and the government of the exporting country (region).
• The Ministry of Commerce may use questionnaires, sampling, hearings, on-site inspections and other methods to understand the situation and conduct investigations with stakeholders. It shall provide relevant stakeholders with an opportunity to present their opinions and arguments. If the Ministry of Commerce deems it necessary, it may dispatch staff to the relevant country (region) to conduct an investigation, unless the relevant country (region) raises objections.
• Based on the investigation results, the Ministry of Commerce will make a preliminary ruling on whether dumping, injury and the causal relationship between the two are established and announce it.
• If the preliminary ruling establishes dumping, injury and the causal relationship between the two, the Ministry of Commerce shall continue its investigation into dumping and the margin of dumping, injury and the extent of injury, and make a final ruling based on the findings, which shall be announced. Before making the final ruling, the Ministry of Commerce shall notify all known interested parties of the basic facts on which the final ruling is based.
• Time limit – an anti-dumping investigation shall be concluded within 12 months from the date of announcement of the decision to initiate an investigation; it may be extended under special circumstances, but the extension period shall not exceed six months.
• The Ministry of Commerce will make recommendations for the imposition of anti-dumping duties. The State Council Tariff Commission will make decisions based on the recommendations, which will be announced by the Ministry of Commerce. Customs will implement the decisions starting from the date of implementation of the announcement.

There is a similar process for investigating and imposing countervailing duties and taking safeguard measures.

During anti-dumping proceedings, the Ministry of Commerce, based on the results of its investigation, will make a preliminary ruling on whether dumping, injury and the causal relationship between the two have been established, and will announce the decision. If the preliminary ruling determines that dumping, injury and the causal relationship between the two have been established, the Ministry of Commerce shall continue its investigation into dumping and the margin of dumping, injury and the extent of injury, and make a final ruling based on the results of the investigation, and announce the decision.

There are similar provisions in countervailing and safeguard procedures.

There are no jurisdictions in China where the authorities cannot or will not impose AD/CVD duties or safeguards.

In the anti-dumping procedure, the period for imposing anti-dumping duties and the period for fulfilling price undertakings shall not exceed five years; however, if it is determined upon review that the termination of the imposition of anti-dumping duties is likely to lead to the continuation or recurrence of dumping and injury, the period for imposing anti-dumping duties may be appropriately extended.

There are similar provisions in countervailing and safeguard procedures.

In anti-dumping proceedings, after anti-dumping duties take effect, the Ministry of Commerce may, if justified, decide to review the necessity of continuing to impose them. It may also, after a reasonable period of time, upon the request of an interested party and after reviewing the relevant evidence provided by the interested party, decide to review the necessity of continuing to impose them. After a price undertaking takes effect, the Ministry of Commerce may, if justified, decide to review the necessity of continuing to honour it. It may also, after a reasonable period of time, upon the request of an interested party and after reviewing the relevant evidence provided by the interested party, decide to review the necessity of continuing to honour it. Based on the results of the review, the Ministry of Commerce shall, in accordance with the provisions of the relevant Regulations, make a recommendation to retain, modify or cancel the anti-dumping duties. The State Council Tariff Commission shall make a decision based on the Ministry of Commerce’s recommendation, which shall be announced by the Ministry of Commerce.

Alternatively, the Ministry of Commerce may make a decision to retain, modify or cancel the price undertaking in accordance with the provisions of these Regulations and announce it. The review procedure shall be conducted in accordance with the relevant provisions of the Regulations regarding anti-dumping investigations and shall not exceed 12 months from the date of the decision to commence the review. During the review period, the review procedure does not hinder the implementation of anti-dumping measures.

There are similar provisions in countervailing and safeguard procedures.

Relevant laws and regulations do not provide for a specific appeal procedure, but the review procedure mentioned in 5.10 Review Process can be understood as a type of appeal procedure. This is because, according to relevant laws and regulations, the Ministry of Commerce may, upon request from an interested party and after reviewing the relevant evidence provided by the interested party, decide to review the necessity of continuing to impose anti-dumping duties.

There are similar provisions in anti-subsidy procedures.

The Ministry of Commerce of China has studied and drafted the Anti-Circumvention Rules on Trade Relief Measures (Draft for Comments) and published it on the Ministry of Commerce website on 30 July 2025, soliciting public opinions.

Trade conflicts and uncertainties are likely to persist in international trade over the next 12 months. China will further improve its legislation and strengthen its crackdown on circumvention.

In China, foreign investment that affects or may affect national security is subject to security review in accordance with relevant laws and regulations. China has established a working mechanism for foreign investment security review, responsible for organising, co-ordinating and guiding this work. The working mechanism’s office is located within the National Development and Reform Commission (NDRC), and is led by the NDRC and the Ministry of Commerce. It oversees the day-to-day work of foreign investment security review.

The security review process is as follows.

• When parties apply for foreign investment to the Working Mechanism Office, they shall submit relevant materials in accordance with the relevant provisions of laws and regulations.
• Within 15 working days of receiving the materials that meet the requirements submitted by the parties or forwarded by the relevant departments of the provincial, autonomous regional or municipal people’s government, the office makes a decision on whether a security review is required for the foreign investment application and notifies the parties in writing. Before the working mechanism office makes a decision, the parties may not implement the investment. If the working mechanism office decides that a security review is not necessary, the parties may implement the investment.
• Foreign investment security reviews are divided into general reviews and special reviews. If the Working Mechanism Office decides to conduct a security review of a declared foreign investment, it shall complete the general review within 30 working days from the date of the decision. During the review period, the parties concerned may not make any investment. If, after the general review, the Working Mechanism Office determines that the declared foreign investment does not affect national security, it shall approve the security review. If it determines that the declared foreign investment does or may affect national security, it shall initiate a special review. The Working Mechanism Office shall notify the parties concerned of its decision in writing. If the Working Mechanism Office decides to initiate a special review of a declared foreign investment, it shall make a decision in accordance with the following provisions after the review and notify the parties concerned in writing:
• if the declared foreign investment does not affect national security, it shall approve the security review;
• if the declared foreign investment affects national security, it shall prohibit the investment; and
• if the impact on national security can be eliminated by adding conditions and the parties concerned have committed in writing to accept the additional conditions, it may grant a conditional approval of the security review, and the additional conditions shall be listed in the decision.

The special review shall be completed within 60 working days from the date of initiation; the review period may be extended in special circumstances. The parties concerned shall be notified of any extension of the review period in writing. During the review period, the parties concerned may not make any investment.

The same applies to investments made by investors from the Hong Kong Special Administrative Region, the Macao Special Administrative Region and Taiwan that affect or may affect national security.

The state has established a working mechanism for foreign investment security reviews, responsible for organising, co-ordinating and guiding this work. The working mechanism’s office, located within the NDRC, is spearheaded by the NDRC and the Ministry of Commerce and is responsible for the day-to-day work of foreign investment security reviews. Decisions on foreign investment security reviews will be overseen and implemented by the working mechanism’s office in conjunction with relevant departments and local people’s governments.

Foreign investors or relevant domestic parties must proactively report foreign investment within the following categories to the Office of the Working Mechanism before implementing the investment:

• investment in military industry, military industry supporting facilities and other sectors related to national defence security, as well as investment in areas surrounding military facilities and military industrial facilities; and
• investment in important agricultural products, important energy and resources, major equipment manufacturing, important infrastructure, important transportation services, important cultural products and services, important information technology and internet products and services, important financial services, key technologies, and other important sectors related to national security, and obtaining actual control of the invested enterprise.

Obtaining actual control of the invested enterprise includes the following circumstances:

• a foreign investor holds more than 50% of the enterprise’s equity;
• a foreign investor holds less than 50% of the enterprise’s equity, but the voting rights enjoyed by the foreign investor can significantly influence the resolutions of the board of directors, shareholders’ meeting, or general meeting of shareholders; and
• other circumstances that give the foreign investor significant influence over the enterprise’s operational decisions, personnel, finances, technology, etc. The Office of the Working Mechanism has the authority to require the parties involved to report foreign investment within the scope of the first paragraph.

For foreign investment within a specific scope, foreign investors or relevant domestic parties should proactively report to the working mechanism office before implementing the investment.

Relevant laws and administrative regulations do not specify which projects or teams are exempt from review. Generally speaking, foreign investment that affects or may affect national security must be declared and reviewed in accordance with laws and regulations.

Potential penalties and consequences may include orders from the working mechanism office to declare within a specified timeframe; orders to dispose of equity or assets within a specified timeframe and take other necessary measures to restore the investment to its pre-investment status and eliminate any impact on national security; revocation of relevant decisions; and orders to rectify the situation. Furthermore, related behaviour may be recorded as a negative credit record in the relevant national credit information system, subject to joint penalties in accordance with relevant national regulations.

In China, certain fees are required to be paid during the investment security review or filing process. These fees include, but are not limited to, the following:

• performance bond – credit guarantee fees paid for signing investment agreements;
• intermediary service fees – professional service fees including legal counsel, financial consulting and asset valuation;
• exploration and research expenses – costs related to resource exploration, market research, feasibility studies, etc;
• letter of guarantee processing fee – fees charged by banks for issuing letters of guarantee to enterprises; and
• other compliance expenses – third-party fees such as notarisation, certification, translation and document processing.

In 2024, the Ministry of Commerce, China Securities Regulatory Commission, State-Owned Assets Supervision and Administration Commission of the State Council, State Taxation Administration, State Administration for Market Regulation, and State Administration of Foreign Exchange jointly issued the Administrative Measures for Strategic Investments in Listed Companies by Foreign Investors. These measures took effect on 2 December 2024. They stipulate that “where strategic investments by foreign investors in listed companies affect or may affect national security, security reviews shall be conducted in accordance with the Administrative Measures for Security Review of Foreign Investment and other relevant regulations”.       

In the future, China may further refine its legislation on investment security reviews, detailing the specific scope and workflow of key areas. Furthermore, China may also publish more relevant cases to guide relevant practices.

On 27 June 2025, the Ministry of Finance, the State Administration of Taxation and the Ministry of Commerce jointly issued the Announcement on the Tax Credit Policy for Direct Investment by Overseas Investors with Distributed Profits, which clearly stipulates that during the period from 1 January 2025 to 31 December 2028, overseas investors who use profits distributed by resident enterprises in China for direct investment in China can enjoy tax credits if they meet the conditions.

Standards (including standard samples) refer to unified technical requirements in fields such as agriculture, industry, services and social services. Chinese standards include national standards, industry standards, local standards, group standards and enterprise standards. National standards are categorised as mandatory and recommended, while industry and local standards are recommended. Mandatory standards must be followed. China encourages the adoption of recommended standards.

No standards or other technical requirements specifically designed to reduce imports and/or encourage domestic production have been identified in China at this time.

To date, no sanitary and phytosanitary requirements specifically designed to reduce imports and/or encourage domestic production have been identified in China. The Law of the People’s Republic of China on Entry and Exit Animal and Plant Quarantine (2009 Amendment) was enacted to prevent the entry and exit of infectious and parasitic animal diseases, dangerous plant diseases, insects, weeds and other harmful organisms, to protect agricultural, forestry, animal husbandry, and fishery production and human health, and to promote the development of foreign economic and trade relations.

To date, no competition policy or price controls specifically designed to reduce imports and/or encourage domestic production have been identified in China. According to the Foreign Investment Law of the People’s Republic of China, China adheres to its fundamental national policy of opening up to the outside world and encourages foreign investors to invest in China in accordance with the law. The country implements high-level investment liberalisation and facilitation policies, establishes and improves mechanisms to promote foreign investment, and fosters a stable, transparent, predictable and fair market environment.

To date, no state trading, state-owned enterprises and privatisation measures specifically aimed at reducing imports and/or encouraging domestic production have been identified in China. According to the relevant provisions of the Foreign Investment Law of the People’s Republic of China, the Chinese state protects the investments, returns and other lawful rights and interests of foreign investors within China in accordance with law. The state does not expropriate foreign investors’ investments. In exceptional circumstances, the state may, in accordance with law, expropriate or requisition foreign investors’ investments for the public interest. Such expropriation or requisition shall be carried out in accordance with legal procedures, and fair and reasonable compensation shall be provided promptly.

To date, there is no known effective “buy national/local” requirement in China specifically designed to reduce imports and/or encourage domestic production.

According to the relevant provisions of the Foreign Investment Law of the People’s Republic of China, China adheres to the fundamental national policy of opening up to the outside world and encourages foreign investors to invest in China in accordance with the law. The state implements high-level investment liberalisation and facilitation policies, establishes and improves foreign investment promotion mechanisms, and fosters a stable, transparent, predictable and fair market environment. The state guarantees that foreign-invested enterprises participate in government procurement activities through fair competition in accordance with the law. Government procurement treats foreign-invested enterprises equally in accordance with the law regarding products produced and services provided by them in China.

To date, no geographical indication protection measures specifically aimed at reducing imports and/or encouraging domestic production have been identified in China.

How to effectively develop international trade agreements and national international trade laws to reduce global trade conflicts and policy uncertainties that worsen the global economic outlook is a crucial and worthy topic for discussion.