Unreliable Entities List

Sanctions of the government of the People's Republic of China are financial and trade restrictions imposed against individuals, entities, and jurisdictions whose actions it has determined to be contrary to certain national interests. China maintains three unilateral sanctions programs in addition to implementing the multilateral sanction decisions adopted by the United Nations Security Council.

China's three unilateral sanctions programs are separately administered by the Ministry of Foreign Affairs, Ministry of Commerce, and the Taiwan Affairs Office. The Ministry of Foreign Affairs maintains a sanctions list that imposes travel, trade, and financial restrictions against targeted individuals and entities accused of interfering with China's domestic affairs or endangering China's interests. The Ministry of Commerce maintains the "Unreliable Entity List", which heavily restricts allowable business and investment activity in China by listed entities. The Taiwan Affairs Office implements sanctions against Taiwan and targets entities and individuals accused of promoting Taiwanese independence.

Economic sanctions have become an increasingly common instrument in China's foreign policy, particularly as the country's economic power has grown in recent years. Compared to Western sanctions—typically led by the United States and the European Union—China's use of economic sanctions exhibits several notable differences. Influenced by international norms, domestic political and economic structures, and concerns over its international reputation, China tends to employ sanctions in a more restrained and low-profile manner. Although the frequency of Chinese sanctions has risen significantly in recent years, it remains relatively rare for China to impose sanctions as proactively or publicly as Western powers. Several key characteristics distinguish Chinese economic sanctions:

1. Ambiguous and informal announcements

Unlike in Western countries, Chinese sanctions are not typically imposed through clear legal or administrative orders. Instead, they are often announced via statements by relevant government agencies, serving to create a sense of threat or coercion. For this reason, scholars frequently describe Chinese sanctions as "informal sanctions". A notable example is the dispute between China and South Korea over the deployment of the THAAD missile defense system in 2016. In response, Chinese authorities ordered the suspension of 74 Lotte supermarkets for fire safety violations and informally blacklisted several South Korean companies, effectively halting commercial interactions. These measures lacked formal legal basis but had tangible punitive effects.

This ambiguity allows the Chinese government greater policy flexibility. However, the pattern began to shift following the U.S.–China trade war, as China introduced a series of legal instruments—such as the Unreliable Entity List and the Anti-Foreign Sanctions Law—to formalize and legitimize its use of sanctions. Despite these developments, many sanctions continue to be issued through diplomatic statements without formal legal codification.

In September 2020, the Ministry of Commerce issued new rules allowing for the creation of the , and the National People's Congress followed up soon after in June 2021 by promulgating the Anti-Foreign Sanctions Law, which established a legal framework for maintaining previous sanctions. The law also allowed Chinese ministries, such as the Ministry of Foreign Affairs and the Taiwan Affairs Office, to implement new blocking sanctions against foreign individuals and entities. The Taiwan Affairs Office announced a sanction under the new law in November 2021, and the Ministry of Commerce announced its first Unreliable Entity List designation in February 2023.

2. Focus on specific issues

Chinese sanctions are often closely tied to issues of diplomacy and national sovereignty; for example, the rare earth export ban on Japan amid the Diaoyu/Senkaku Islands dispute and agriculture import ban on Taiwan during Nancy Pelosi's visit to Taiwan. In practice, Chinese economic sanctions tend to be more symbolic than substantive—frequently described as "more bark than bite." They are often short in duration but intense in impact, aiming to compel the target to yield quickly under pressure.

3. Focus on individuals, corporations, and public mobilization

Chinese sanctions are primarily directed at foreign individuals and companies, rather than foreign governments—a notable contrast to the approaches of the United States or the European Union, which sometimes target entire governments. In addition, China often encourages its domestic population to reduce consumption of goods from the targeted country, thereby enhancing the impact of sanctions through patriotic appeals. This strategy blends state action with public participation to amplify pressure on the target.

As of August 2024, over 100 individuals and entities have been sanctioned by China.

Scholars have created Chinese Economic Sanctions database from 1949 to 2020, including 135 cases in which China is the sender and 88 cases in which China is the target, and the dataset can be downloaded on GitHub.

Sanctions announced by the Ministry of Foreign Affairs

Sanctions announced by the Ministry of Commerce (Unreliable Entities List)

Sanctions announced by the Taiwan Affairs Office

Enforcement of UN Security Council sanctions resolutions

Notes

References

{{Foreign relations of China

Foreign relations of China
Embargoes
Chinese foreign policy