Navigating China’s Evolving Legal Toolkit For Countermeasures: Practical Implications And Future Outlook

In April 2026, the State Council of China consecutively issued the Regulations of the State Council on Industrial and Supply Chain Security (the“Industrial and Supply Chain Security Regulations”) and the Regulations of the People’s Republic of China on Countering Unjustified Extraterritorial Jurisdiction (the“Countering Extraterritorial Jurisdiction Regulations”).

Shortly afterward, on May 2, China’s Ministry of Commerce (“MOFCOM”) issued, under the Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures(the “Counteracting Rules”), the first formal blocking order targeting U.S. measures. The recent wave of legislation and enforcement has not only sparked market debate but also spotlighted the evolving structure and priorities of China’s countermeasure legal framework. For businesses, navigating this framework has become a key aspect of cross-border compliance.