China Decree 835
国务院令第835号 — Regulations of the PRC on Countering Improper Foreign Extraterritorial Jurisdiction
Topic : Governance · Level : National
Today
In force on publication (13 Apr 2026). MOJ named 2 measures: Nuctech (15 May) and JD.com (19 Aug 2026) EU FSR requests.
Summary
China's regulation against improper foreign extraterritorial jurisdiction, in force since 13 April 2026. The Ministry of Justice can block specific foreign measures; no one in China may implement them. Two EU-related cases were named in 2026.
Who is concerned
- Turnover
- non précisé
- Employees
- non précisé
- Listed company
- cotées et non cotées
- Sectors
- All sectors
- Triggering activities
- Implementing a foreign measure MOJ blocked
- Promoting improper foreign jurisdiction
- Operating in mainland China
- Extraterritorial reach
- Yes
Applies to foreign firms and their PRC subsidiaries that implement or assist a blocked foreign measure.
- Examples
- PRC subsidiary of an EU group
- Foreign auditor relaying a regulator's request
- HQ decision to cut a Chinese supplier
What the law requires
- Do not implement or assist a foreign measure MOJ has blocked, unless exempted
- Escalate foreign legal requests touching China operations for PRC review
- Keep records of decisions affecting Chinese counterparties
- Seek an exemption before complying with a blocked measure
Penalties
Limits on procurement, trade, data transfers, entry; fines; listed foreign entities face asset freezes and entry bans. Private damages suits.
What this changes for a supplier in China
A Chinese supplier may refuse to execute a blocked foreign measure and can sue for damages. Buyers' requests flowing from foreign rules need legal screening.
Expected evidence
- Written basis for each data request
- Legal review of cross-border transfers
- Exemption file if a blocked measure applies
Tiers : Tier 1-N