Operating in China
China restricted supply chain investigations in 2026.
Most buyers are now caught between two sets of obligations. Before you commission anyone, ourselves included, you should know which activities are exposed and which are permitted.
In force since April 2026
Decree 834 — Provisions on the Security of Industrial and Supply Chains. Article 13 addresses investigations and information collection carried out inside China in violation of Chinese law, and applies even where the activity is described as commercial due diligence.
Decree 835 — Regulations on Countering Improper Foreign Extraterritorial Jurisdiction. Prohibits executing or assisting foreign measures identified as improper, and establishes a list of entities subject to countermeasures.
The line
Exposed and permitted activity
Exposed
- Intrusive or unannounced factory verification
- Unsupervised interviews with workers
- Photography and sampling beyond what the site has agreed
- Any of the above in politically sensitive regions
- Moving diligence data out of China without a legality review
Permitted
- Ordinary commercial due diligence, including commercial credit checks
- Verification of provenance by lawful means
- Documentation the supplier provides
- Remote video walkthroughs the supplier hosts and has agreed to
- Site visits the supplier has invited and hosts, kept to agreed areas
Based on published legal analysis of Decrees 834 and 835. Not legal advice.
How this shapes the work
Designed to the permitted standard, not against it
Our core work, reading public corporate and court filings and forming a commercial judgement, sits squarely within the permitted category. It is a commercial credit check and always has been.
You commission us; the supplier hosts us. Before every visit we obtain written confirmation that the visit is agreed, that a named member of their team will be present, which areas we may see, and what we may photograph. We do not interview workers. We photograph nothing outside what was agreed. The host is offered a copy of our observations.
Work we decline
Forced-labour audits, and anything touching politically sensitive regions.
This is the precise point where Western supply chain mandates and Chinese blocking rules conflict. We will say we cannot help rather than take the fee and expose both of us.
This page describes how we work. It is not legal advice. If your own obligations require diligence we have said we will not perform, take advice from counsel qualified in both jurisdictions.