Two Ministry of Commerce orders issued on the same day prohibit organisations and individuals in China from transacting or cooperating with seven US entities. One is the Responsible Business Alliance, parent of the Responsible Minerals Initiative, whose templates and audit programme underpin conflict-minerals due diligence across this industry. Another is a conformity-assessment laboratory.
What Happened
Ministry of Commerce Order No. 2 of 2026, 关于对应用DNA科学公司等6家美国实体采取反制措施的决定 (Decision on Countermeasures Against Six US Entities Including Applied DNA Sciences, Inc.), took effect on 5 August 2026. The six listed entities are Applied DNA Sciences, Inc. (Stony Brook, NY); Stratum Reservoir, LLC (Houston, TX); Altana Technologies, Inc. (Brooklyn, NY); Responsible Business Alliance (Alexandria, VA); Verite Group, Inc. (Sterling, VA); and Human Rights in China (New York, NY). Order No. 3 of 2026, 关于对美国合规性测试公司采取反制措施的决定 (Decision on Countermeasures Against U.S. Compliance Testing Companies), took effect the same day and names Compliance Testing LLC, also known as Compliance Testing or CT, of 1724 S Nevada Way, Mesa, Arizona. Both orders prohibit organisations and individuals within Chinese territory from engaging in transactions, cooperation and other activities with the listed entities. The stated justifications are, respectively, US sanctions against Chinese enterprises based on forced-labour allegations, and US Federal Communications Commission actions the laboratory is said to have assisted.
What’s New
- First designation of a major responsible-sourcing scheme owner under China’s counter-sanctions framework.
- The prohibition binds parties inside China — it is Chinese suppliers, smelters and refiners that are barred from cooperating, not the OEM outside China.
- Verite Group, a social-audit provider widely used in supply chain labour assessments, is listed alongside the RBA.
- A conformity-assessment laboratory, rather than a manufacturer or technology company, is the target of Order No. 3 — a new category of risk in homologation and certification planning.
- Neither order imposes an asset freeze or entry ban.
Key Dates & Timeline
Orders No. 2 and No. 3 of 2026 issued and effective
No expiry stated in either order
Affected Industries
All · Light duty vehicles · Heavy duty vehicles · Batteries · Electrical and electronic equipment · Powertrain · Smelting and refining · Radio and telematics modules
Who Is Affected
OEMs and Tier-n suppliers running conflict-minerals and battery due-diligence programmes; Chinese smelters, refiners and suppliers asked to participate in RBA or RMI activities; manufacturers using US-based EMC, radio and product-safety test laboratories; Chinese subsidiaries arranging testing; procurement, sustainability, homologation and legal functions.
Standards / Products in Scope
Transactions and cooperation activities between parties within Chinese territory and the seven listed US entities.
Prohibitions, Restrictions & Requirements
Organisations and individuals within Chinese territory are prohibited from engaging in relevant transactions and cooperation activities with the listed entities. Testing or due-diligence activity arranged wholly from outside China is not itself prohibited by the orders, but a Chinese entity in the chain of instruction may be caught.
What Companies Should Do
- Do not instruct Chinese suppliers to participate in RBA or RMI activities without taking legal advice first — the prohibition binds them, and a well-meant data request can put a supplier in breach of Chinese law.
- Re-baseline your smelter and refiner list and identify which facilities are China-domiciled, since their participation in the audit programme is now constrained.
- Check whether any Chinese entity in your group or supply chain is the contracting party for testing at Compliance Testing LLC; if so, re-route the engagement through a non-Chinese entity or an alternative laboratory and record the reason.
- Add counter-sanctions screening to laboratory and certification-body selection, alongside your existing supplier screening.
The failure mode here is mundane rather than dramatic: a Chinese subsidiary or supplier doing something entirely lawful for the parent and unlawful for them. Both orders bind the party inside China, so the compliance work is in what you ask Chinese entities to do, not in what you do yourself.
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