Ministry of Commerce of the People's Republic of China Order No. 2 of 2026: Decision on Countermeasures Against 6 U.S. Entities Including Applied DNA Sciences, Inc.

China's Retaliatory Stance on Xinjiang Sanctions

The Ministry of Commerce of the People's Republic of China has formally announced a decision to implement countermeasures against six U.S. entities, citing their alleged involvement in supporting U.S. sanctions related to Xinjiang. This move is presented as a direct response to what China describes as the United States' "serious violation of international law and basic norms of international relations" through its "forced labor" sanctions against Chinese enterprises. The Chinese government views these U.S. actions as a severe infringement upon its sovereignty, security, and development interests, signaling a firm resolve to protect its domestic policies and economic activities from foreign interference. This latest development underscores the escalating tit-for-tat dynamic in U.S.-China relations, where economic measures are increasingly weaponized in geopolitical disputes.

The Targeted U.S. Entities and Their Implications

The list of six U.S. entities includes a mix of commercial companies and non-profit organizations, indicating a broad scope for China's retaliatory measures. Applied DNA Sciences, Inc., Stratum Reservoir, LLC., Altana Technologies, Inc., and Verite Group, Inc. are commercial entities, while the Responsible Business Alliance (RBA) and Human Rights in China (HRIC) are non-governmental organizations. The countermeasures specifically prohibit Chinese organizations and individuals from engaging in "relevant transactions, cooperation, and other activities" with these listed entities. The inclusion of the Responsible Business Alliance, a major industry coalition focused on supply chain sustainability and corporate social responsibility, is particularly noteworthy. This suggests China is targeting not only direct commercial actors but also organizations that influence global supply chain standards and human rights due diligence, effectively challenging the legitimacy of such frameworks when they touch upon Chinese domestic issues.

Intensifying Geopolitical Friction and Economic Risks

This decision by China's Ministry of Commerce further intensifies the already strained relationship between Beijing and Washington. By invoking its Anti-Foreign Sanctions Law, China is demonstrating its legal framework for counter-sanctions, a tool it has increasingly utilized to push back against perceived foreign aggression. The move sends a clear message that China will not passively accept foreign sanctions, especially those based on human rights allegations it vehemently denies. For businesses and organizations with operations or interests in both the U.S. and China, this escalating cycle of sanctions creates significant operational and compliance risks. It forces entities to navigate a complex and increasingly bifurcated global economic landscape, potentially leading to difficult choices regarding market access, supply chain integrity, and adherence to international standards versus national regulations. The long-term implications could include further decoupling of economies and increased uncertainty for global trade and investment.