China formalizes supply chain security investigation regime under MOFCOM
Multinational manufacturers and exporters must map exposure as MOFCOM gains authority to probe foreign trade restrictions and discriminatory practices targeting Chinese supply chains.
On June 24, 2026, MOFCOM issued Announcement No. 24, operationalizing the State Council's March 2026 Regulation on Industrial and Supply Chain Security. The Measures create a formal investigation mechanism targeting two categories of conduct: discriminatory or restrictive measures imposed by foreign governments or international organizations on Chinese supply chains, and actions by foreign organizations or individuals that disrupt transactions with Chinese entities or adopt discriminatory practices causing substantial harm. MOFCOM may initiate investigations ex officio or based on stakeholder submissions, assessing impacts on critical materials, technology, capital, data, personnel, logistics, finance, and information flows. A cross-departmental coordination mechanism led by the State Council—spanning MOFA, NDRC, MIIT, Customs, and the Cyberspace Administration—signals a whole-of-government enforcement posture. Companies with significant China-based operations, suppliers, or customers should assess contractual exposure, document supply chain dependencies, and prepare for potential information requests or countermeasures tied to foreign sanctions or export controls.