State Council Order No. 834 and Decree No. 835 took effect on April 7 and April 13, 2026, with no transition period, allowing Chinese authorities to investigate and penalize foreign entities deemed harmful to supply chain security.
The regulations create legal risks for foreign companies, especially those balancing U.S. compliance obligations, by enabling China to treat routine supply chain audits or forced labor checks as discriminatory or politically motivated acts.
These measures intensify conflict-of-laws challenges, raise exit-ban risks for foreign personnel, and reflect Beijing’s response to U.S. sanctions and de-risking policies, fundamentally altering how global firms must manage China-related compliance and procurement decisions.
China's new laws punish compliance with US rules. How can companies avoid being legally trapped between two superpowers?
Are foreign executives now facing exit bans in China for simply following their company's compliance policies?
As China criminalizes UFLPA compliance, is the US law losing its power to fight forced labor?
Are Beijing's new regulations the first step toward forcing a complete split in global supply chains?
With due diligence now a national security risk, is a 'China-Plus-One' strategy enough for global companies?