The New Foreign Trade Law of the People’s Republic of China (2025 Revision):Towards a More Strategic, Secure and Coordinated Foreign Trade Framework

With the 2025 Revision of the Foreign Trade Law of the People’s Republic of China (中华人民共和国对外贸易法), adopted on 27 December 2025 and scheduled to enter into force on 1 March 2026, China takes a significant step in the evolution of its international trade regulatory framework.

This reform goes well beyond a mere technical update. It reflects a systemic rethinking of the role of foreign trade, which is now explicitly framed within the broader priorities of national security, industrial development and economic governance.

The Law consists of 83 articles, structured into 11 chapters, and provides a comprehensive regulatory architecture governing foreign trade activities.

One of the most striking features of the 2025 Revision is the explicit reinforcement of the connection between foreign trade and national security. The Law clarifies that import and export activities must be assessed not only from an economic perspective, but also in light of economic security, the security of supply chains, and the protection of strategic industrial interests.

This approach results in enhanced regulatory intervention powers for the competent authorities, particularly in sensitive sectors such as advanced technologies, data and critical resources.

The reform also modernises import and export controls by consolidating and aligning the Foreign Trade Law with China’s most recent legislation on export controls and dual-use items. It introduces clearer criteria for the adoption of restrictive measures, stronger integration between administrative authorisations, control lists and risk assessment mechanisms, as well as a more systematic and structured approach to corporate compliance.

The outcome is a regulatory system that is more coherent and transparent, but also more demanding for economic operators, including foreign companies active in the Chinese market.

The 2025 Revision places increased emphasis on the role of companies as primary actors in safeguarding legality in international trade. In particular, it encourages the adoption of internal control and compliance systems, procedures for assessing commercial and regulatory risks, and structured mechanisms for cooperation with public authorities.

This marks a clear shift from a predominantly sanction-based approach to a preventive and cooperative model, while maintaining a robust sanctions regime in cases of non-compliance.

The reform further strengthens coordination among the various authorities involved in foreign trade regulation, including trade, customs, security and technology authorities, with the aim of reducing overlaps and interpretative uncertainties. The declared objectives are to improve administrative efficiency, the predictability and consistency of regulatory decisions, and the capacity to respond promptly to crises or periods of heightened international tension.

Alongside the expansion of public regulatory powers, the Law introduces more articulated safeguards for economic operators. These include increased attention to procedural transparency, specific protection mechanisms for operators affected by restrictive measures, and clearer procedures for review and appeal. Together, these elements reflect an effort to strike a balance between state control and legal certainty, a key factor for the overall attractiveness and credibility of the system.

In conclusion, the 2025 Revision of the Foreign Trade Law signals a shift towards a model of strategic foreign trade law, in which liberalisation, security considerations and public governance are no longer treated as separate dimensions, but as components of a single, integrated regulatory framework.

From a practical perspective, for both Chinese and foreign companies, the reform entails increased compliance obligations, the need for an integrated reading of trade, technology and security-related regulations, and a more structured and informed approach to operating in the Chinese market.

Ultimately, this reform represents not merely an update of foreign trade legislation, but a core element of China’s evolving legal and economic architecture in the global context.