Since the inauguration of the second Trump administration, trade tensions between the United States (the “US”) and China have intensified. In response to US measures against China, such as tariff hikes and export controls on advanced semiconductors, China continued to counter with its own export controls and sanctions against US companies. These tensions between the two countries appeared to have temporarily subsided following an agreement reached in November 2025.
However, the summit between President Trump and President Xi held in Beijing last month concluded without a clear breakthrough, and China has begun to actively employ countermeasures—including sanctions applicable to foreign companies.
Amid this rapidly changing geopolitical landscape, companies need to review China’s recent foreign and trade policies to proactively prepare for potential supply chain and compliance risks they may face in the future.
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1. |
US–China Summit (May 14 to 15, 2026) |
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A. |
Key Outcomes (Trade and Investment) |
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B. |
Media Reactions |
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2. |
Recent Chinese Foreign Policy and Trade Policy Measures |
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A. |
Export Control Against Japan |
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a. |
Prohibition of Dual-Use Item Exports (January 2026): The Chinese government has imposed a complete ban on the export to Japan of dual-use items that could be used by the Japanese military or contribute to the enhancement of Japan’s military capabilities.[5] The MOFCOM has warned that it will hold any party—regardless of country or region—legally accountable for violations of these regulations. Therefore, Korean companies should exercise caution, as they may face legal liabilities under Chinese law if they import regulated Chinese goods and re-export the goods to Japan. |
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b. |
Additions to Export Control and Watch Lists (February 2026): The Chinese government has added more than 40 Japanese defense-related companies and organizations to its Export Control List and Watch List.[6] Exports of Chinese goods to these organizations have been strictly banned, and the review process for export permits has been tightened. |
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B. |
Measures Against Unfair Extraterritorial Application and Countersanctions |
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a. |
Prohibition of Compliance With US Sanctions (May 2, 2026): In response to the US government’s designation of Chinese companies that purchased and transported Iranian oil as entities subject to sanctions (Specially Designated Nationals List, “SDN”)[7], the MOFCOM issued an enforcement order based on the Measures to Prevent the Improper Extraterritorial Application of Foreign Laws and Measures ( effective January 2021), completely prohibiting the authorization, enforcement or compliance with these US sanctions within China.[8] |
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b. |
Prohibition of Cooperation With EU’s Foreign Subsidies Regulation (“FSR”) Investigations (May 16, 2026): The Chinese Ministry of Justice, citing the Regulations on Countering Unjustified Extraterritorial Jurisdiction by Foreign Countries (effective April 2026), has designated the ongoing EU FSR investigation, currently being conducted by the EU’s executive arm, the European Commission, against Chinese companies as an “unjustified extraterritorial jurisdiction measure.”[9] It also prohibited all companies operating within China as well as individuals from cooperating with the EU’s investigation.[10] |
The measures implemented by China may apply not only to Chinese companies but also to foreign companies and individuals. Therefore, if companies or individuals from foreign countries violate these measures by complying with US sanctions or cooperating with EU investigations, they may face direct sanctions from the Chinese government, such as asset freezes or transaction bans.
As noted earlier, the recent US–China summit failed to yield tangible results in resolving the trade dispute between the two countries. With President Xi’s planned visit to the US in September, the US midterm elections in November, and the expiration of temporary mutual tariff reductions on the horizon, uncertainty in the international trade environment is expected to persist for the foreseeable future in the second half of this year.
It is important to note that, as the level of pressure from major powers such as the US and the EU intensifies, China’s response has become increasingly assertive. China has established an institutional foundation to counter foreign measures and sanctions against it through the enactment and amendment of laws such as the Foreign Trade Law and Foreign Relations Law. Furthermore, China has formulated specific countermeasures by issuing the detailed regulations mentioned earlier. These measures are significant in that they represent the first instances of enforcement under these regulations.
On the other hand, President Trump hinted that some agreement had been reached regarding sanctions during the summit, but to date, no specific easing measures or guidelines have been announced to support this. Consequently, a clash has emerged between Western countries’ measures to respond to China and China’s countermeasures under its “blocking statutes.”
This situation is exacerbating compliance risks for global companies operating under mutually exclusive trade regulatory environments, and Korean companies are also falling into its direct and indirect sphere of influence. Therefore, companies need to identify potential compliance risks that may arise from the conflict between Western measures against China and China’s countermeasures in advance. They need to conduct thorough supply chain checks and develop preemptive trade compliance strategies to prepare for scenarios involving regulatory conflicts among different countries.
[1] Fact Sheet: President Donald J. Trump Secures Historic Deals with China, Delivering for American Workers, Farmers, and Industry (White House, May 17, 2026)
[2] 構建“中美建設性戰略穩定關系”是最重要政治共識 (People’s Daily Online, May 16, 2026)
[3] 商务部美大司负责人解读中美经贸磋商初步成果 (Ministry of Commerce of the People’s Republic of China, May 20, 2026)
[4] Why Japan PM’s Taiwan remarks escalated tensions with China (Reuters, November 20, 2025)
[5] 商务部公告2026年第1号 关于加强两用物项对日本出口管制的公告 (Ministry of Commerce of the People’s Republic of China , January 6, 2026)
[6] 商务部公告2026年第11号 公布将20家日本实体列入出口管制管控名单 (Ministry of Commerce of the People’s Republic of China, February 24, 2026); 商务部公告2026年第12号 公布将20家日本实体列入关注名单 (Ministry of Commerce of the People’s Republic of China, February 24, 2026)
[7] Iran-related Designations; Issuance of Iran-related General License and Frequently Asked Question; Publication of Iran-related OFAC Alert (US Department of Treasury, May 1, 2026)
[8] 商务部公告2026年第21号 公布关于美国对5家中国企业实施涉伊朗石油制裁措施的阻断禁令 (Ministry of Commerce of the People’s Republic of China, May 2, 2026)
[9] Commission opens in-depth foreign subsidies investigation into Nuctech’s activities in the threat detection systems sector (European Commission, December 11, 2025). On December 11, 2025, the European Commission announced the launch of an in-depth investigation into Nuctech, a security screening equipment company, and expressed preliminary concerns regarding the possibility that the company had received foreign subsidies capable of distorting the EU internal market.
[10] 司法部发布关于欧盟外国补贴调查相关做法构成不当域外管辖的公告 (Ministry of Justice of the People’s Republic of China, May 15, 2025)
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#US China Trade Conflict #US China Summit #International Trade & Customs #2026 Issue 2 #Newsletter




