On October 30 China’s Ministry of Commerce (“MOFCOM”) issued on draft Measures on Dual-use Items Export Control Investigation and Enforcement (the “Draft”), soliciting public comments until November 29, 2026. For the first time, the Draft explicitly sets out procedures for MOFCOM’s own enforcement arm, within its Bureau of Industry, Security, Import and Export Control, to enforce export control regulations through investigative measures, such as interrogation, seizure and detention of relevant items, assets, documents and facilities.…
On October 26, 2026, China’s Ministry of Commerce (“MOFCOM”) published the draft Special Provisions on the Protection of Chinese Trade Secrets, introducing a new sanctions tool targeting foreign infringement of Chinese trade secrets. Once finalized, the rules would authorize MOFCOM to impose sanctions on foreign companies, organizations and individuals where such infringement harms, or poses an actual threat to, China’s sovereignty, security or development interests. MOFCOM may initiate investigations before imposing sanctions, and third parties…
Overview and key takeaways On 16 October 2026, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) and the Ministry of Science and Technology of the People’s Republic of China (“MOST”) issued Announcement [2026] No. 48, seeking public comments until 15 November 2026 on proposed amendments to the Catalogue of Technologies Prohibited or Restricted from Export (the “Catalogue”). The proposal marks a significant evolution of China’s technology export control regime, with more sophisticated…
China has issued two State Council decrees that further develop its legal and institutional framework for responding to foreign measures applied on an extraterritorial basis and for safeguarding the security of industrial and supply chains. Both decrees operate alongside existing instruments, including the Anti‑Foreign Sanctions Law (“AFSL”), China’s blocking rules, and the Unreliable Entities List (“UEL”) regime. Taken together, they further clarify how China approaches conflicts arising from foreign sanctions, export controls, and other extraterritorial…