ESG Gazette, China- July 2026

Summary

• The European Commission officially released the Guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market, which were the supporting implementation guidelines for EU Regulation on Prohibiting Products Made with Forced Labour on the Union Market (EU) 2024/3015, clarifying the regulatory coverage and identification criteria for forced labour across all product categories and every supply chain stage.
• The Measures for the Investigation Work on Industrial and Supply Chain Security was issued by the Ministry of Commerce and took effect on 22^nd June 2026, authorizing the Ministry of Commerce to initiate investigations into discriminatory measures and disruptions of normal transactions by foreign entities, and to adopt responsive measures such as import/export bans and countermeasure lists based on the findings.
• The newly revised Trademark Law of the People's Republic of China will take effect in 2027, aiming to strengthen whole-chain regulation of registration, administration and use.
• To prevent and control pollution, improve the quality of the ecological environment, and promote the advancement of production processes and pollution prevention and control technologies in the textile industry, the Ministry of Ecology and Environment and State Administration for Market Regulation have jointly gazetted the revised Discharge standard of water pollutants for textile industry.
• To further standardize the identification and rectification of soil and groundwater contamination hazards for key soil pollution supervision and management entity, the Ministry of Ecology and Environment has gazetted the Technical guidelines of soil and groundwater contamination hazards identification and rectification for key soil pollution supervision and management entity.
• The Technical specifications for occupational health surveillance was issued by the National Health Commission of the People's Republic of China, it was an important measure to protect the health of laborers and also an important part of occupational health services.
• The Fire safety signs-Part3: Requirements for the installation was jointly issued by the State Administration for Market Regulation and the National Standards Administration, aims to supply a unified basis for the production, testing, supervision and management of various fire safety sign products, promote the improvement of fire prevention and control capabilities of the whole society, and ensure the safety of people's lives and property.

Contents

Comprehensive

• < Guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market >
• < Measures for the Investigation Work on Industrial and Supply Chain Security >
• < Trademark Law of the People's Republic of China >

Environment

• < Discharge standard of water pollutants for textile industry >
• < Technical guidelines of soil and groundwater contamination hazards identification and rectification for key soil pollution supervision and management entity >

Health and Safety

• < Technical specifications for occupational health surveillance > 
• < Fire safety signs-Part3: Requirements for the installation >

Summary of Law Updates:

Comprehensive

1. < Guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market> (2026-06-26)

On 26^th June 2026, the European Commission officially released Guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market, which were the supporting implementation guidelines and established based on EU Regulation on Prohibiting Products Made with Forced Labour on the Union Market (EU) 2024/3015, and it will be fully applicable as of 14^th December 2027. The Single Information Portal for Forced Labour will be simultaneously launched, to set out practical rules for the formal enforcement of the Regulation.

The Guidelines target competent authorities of EU Member States, customs authorities and economic operators. They clarify that the Regulation applies to all products placed on the EU market, made available on the EU market, or exported from the EU, with no restrictions on industry or country of origin. It covers the full supply chain from extraction, production to processing, and any product involving forced labour (in whole or in part) at any stage will fall under regulatory scope.

The Guidelines refine forced labour identification indicators, covering specific scenarios such as forced recruitment, retention of identity documents, debt bondage, restriction of movement, and non-payment of wages. It also clarifies that distance sales to EU users and products stocked within the EU are both covered by the regulation.

While the Guidelines do not have direct legal binding force, they will serve as the core reference for EU competent authorities to conduct risk screening, evidence verification and law enforcement, and act as a critical reference basis for enterprises to carry out ESG supply chain due diligence and build anti-forced labour systems. The EU is also developing a forced labour risk database, which will gradually disclose information on high-risk regions and high-risk products.

For enterprises exporting to the EU, these guidelines will directly affect the practical standards of ESG supply chain compliance. Relevant enterprises can obtain the latest guidance via the official portal, and sort out full-chain product traceability information in advance.

2. < Measures for the Investigation Work on Industrial and Supply Chain Security > (2026-06-22)

To implement the Provisions of the State Council on Industrial and Supply Chain Security (No. 834) and to effectively conduct investigation work on industrial and supply chain security, the Ministry of Commerce issued Announcement No. 24 of 2026 on 22^nd June 2026, promulgating the Measures for the Investigation Work on Industrial and Supply Chain Security (hereinafter referred to as the Measures), effective as of the date of promulgation.

The Measures stipulate that the Ministry of Commerce is responsible for conducting investigations on industrial and supply chain security. Under the Measures, the Ministry of Commerce may initiate investigations into two types of circumstances: (1) when a foreign country, region, or international organization, in violation of international law, adopts discriminatory prohibitions or restrictions against China with respect to industrial and supply chains; and (2) when a foreign organization or individual, in violation of market transaction principles, interrupts normal transactions with Chinese citizens or organizations, or adopts discriminatory measures, thereby causing substantial harm or threat to China's industrial and supply chain security.

The Measures further specify the dimensions for damage assessment, covering the impact on the security of essential factors such as materials, technology, capital, data, and personnel, and on the unimpeded flow of logistics, commercial flows, capital flows, and data flows. Domestic legal persons and organizations may submit evidentiary materials to the Ministry of Commerce to apply for the initiation of an investigation. Investigation methods include interviewing interested parties, reviewing documents, issuing questionnaires, holding hearings, and conducting on-site investigations. Based on the investigation findings, the Ministry of Commerce may, in conjunction with relevant departments, adopt measures such as prohibiting or restricting imports and exports, restricting investments, and including entities on countermeasure lists; domestic organizations and individuals that fail to comply with such measures may face corresponding penalties.

3. < Trademark Law of the People's Republic of China> (2027-01-01)

The Trademark Law of the People's Republic of China (hereinafter referred to as the new Trademark Law) was adopted on 26^th June 2026 at the 23^rd session of the Standing Committee of the 14^th National People's Congress. This marks the first comprehensive revision since the Law took effect in 1983. The revised Trademark Law has been expanded from 8 chapters with 73 articles to 9 chapters with 87 articles and will officially take effect on 1^st January 2027.

With respect to registration requirements, the new Trademark Law adds a dedicated chapter on "Conditions for Trademark Registration," stipulating that trademark applications filed without intent to use and clearly exceeding normal business needs shall not be registered. Meanwhile, the scope of registrable trademark elements has been broadened to include dynamic marks as registrable subject matter. In addition, it is explicitly provided that iconic elements associated with major theoretical achievements of the Communist Party of China and historical events shall not be used or registered as trademarks.

In terms of trademark administration, the new Trademark Law strengthens penalties for malicious trademark registration applications, with offenders facing warnings and fines of up to RMB 100,000. Regarding long-dormant registered trademarks, the new Law introduces, on top of the existing "non-use revocation for three consecutive years" system, a provision authorizing the trademark administrative department under the State Council to proactively revoke such registrations, thereby improving the mechanism for withdrawal of registered trademarks.

With respect to well-known trademark protection, the new Trademark Law extends cross-class protection to unregistered well-known trademarks, meaning that both registered and unregistered well-known trademarks are entitled to cross-class protection. At the same time, to strengthen the protection of domestic enterprises' rights and interests overseas, the new Law provides that, in trademark cases abroad, confirmation of the well-known status of a trademark may be made upon request.

In terms of agency supervision and rights protection, the new Trademark Law tightens the record-filing management and practice standards for trademark agencies and increases penalties for non-compliant agency practices. Furthermore, the new Law improves the mechanism for coordinating administrative and criminal enforcement in trademark infringement cases and explicitly provides that persons who initiate trademark litigation through malicious collusion or unilateral fabrication of basic facts shall be penalized by the people's courts in accordance with the law.

 

Environment

1. < Discharge standard of water pollutants for textile industry > (GB 4287-2026) (2026-06-11)

The Discharge standard of water pollutants for textile industry (hereinafter referred to as the Standard) has been jointly gazetted by the Ministry of Ecology and Environment and the State Administration for Market Regulation on 11^th June 2026. It will come into force on 1^st September 2026.  

1) The Standard specifies the water pollutant discharge control requirements, monitoring requirements, and supervision and management requirements for textile industry pollutant discharge units and production facilities. This Standard also applies to the management of water pollutant discharge from centralized textile industry wastewater treatment facilities.

2) The Standard is a revision of the Discharge standards of water pollutants for dyeing and finishing of textile industry (GB 4287-2012) and its amendment(s), while also incorporating and revising the Discharge standards of water pollutants for reeling industry (GB 28936-2012), the Discharge standards of water pollutants for woolen textile industry (GB 28937-2012), and the Discharge standards of water pollutants for bast and leaf fibres textile industry (GB 28938-2012). This Standard was first issued in 1992, underwent its first revision in 2012, and this is the second revision. The main contents of this revision are as follows: 

• The standard name has been revised to the Discharge Standard of Water Pollutants for the Textile Industry.
• The applicable scope of the standard has been consolidated and specified.
• Specific applicable scopes for pollutant items have been added, and the discharge limit provisions for certain pollutant items have been adjusted.
• The acute toxicity pollutant items for zebrafish eggs and their corresponding discharge limit provisions have been added.
• The control requirements for indirect discharge of water pollutants have been optimized.
• The provisions on benchmark wastewater discharge per unit of products have been refined and improved.

3) For newly established pollutant discharge units, the provisions of this Standard shall apply to their water pollutant discharges from 1^st September 2026; for existing pollutant discharge units, the provisions shall apply from 1^st January 2028. The relevant provisions in the Discharge standards of water pollutants for dyeing and finishing of textile industry (GB 4287-2012), the Discharge standards of water pollutants for reeling industry (GB 28936-2012), the Discharge standards of water pollutants for woolen textile industry (GB 28937-2012), the Discharge Standard of Water Pollutants for Hemp Textile Industry (GB 28938-2012), and the Integrated Wastewater Discharge Standard (GB 8978-1996) and its corresponding amendment(s) shall no longer be implemented. The Discharge standards of water pollutants for dyeing and finishing of textile industry (GB 4287-2012) and its amendment(s), the Discharge standards of water pollutants for reeling industry (GB 28936-2012), the Discharge standards of water pollutants for woolen textile industry (GB 28937-2012), and the Discharge standards of water pollutants for bast and leaf fibres textile industry (GB 28938-2012) are simultaneously repealed. Existing pollutant discharge units that have negotiated and agreed upon indirect discharge limits may implement this Standard from 1^st September 2026. Local governments may, in accordance with local ecological and environmental protection needs as well as economic and technical conditions, approve the early implementation of this Standard upon approval by the provincial-level people's government. 

2. < Technical guidelines of soil and groundwater contamination hazards identification and rectification for key soil pollution supervision and management entity >（HJ 1478-2026） (2026-06-12)

The Technical guidelines of soil and groundwater contamination hazards identification and rectification for key soil pollution supervision and management entity (HJ 1478-2026) (hereinafter referred to as the Guidelines) has been gazetted by the Ministry of Ecology and Environment on 12^th June 2026. It will come into force on 15^th August 2026, and the Technical guidelines of soil contamination hazards identification and rectification for key soil pollution supervision and management entity (Trial) will be abolished on the same date. 

1) Basic Principles for the Revision of the Guidelines

• Integrating inheritance with development. In terms of inheritance, the Guidelines fully draw upon and incorporate the core content of the trial version, including the overall workflow and key technical points of each stage, thereby maintaining the continuity of the technical system. In terms of development, the Guidelines focus on the typical issues and needs identified during the practice of the 14th Five-Year Plan period, further refining and elaborating the technical requirements on the basis of the trial version to enhance operability.
• Equal emphasis on reducing burden and accountability enforcement. Focusing on genuine hidden dangers and real issues that may cause soil and groundwater contamination, the Guidelines optimize screening targets, streamline deliverable documentation, and, on the premise of ensuring work effectiveness, minimize the burden on enterprises to the greatest extent. Meanwhile, the Guidelines emphasize the enforcement of the hazard screening and remediation system, clarifying that the purpose of establishing the system lies in the implementation of screening and remediation. Accompanying this, quality control points are further detailed to provide a basis for supervision, thereby compelling enterprises to fulfill their responsibilities.

2) Main content of the revision of the Guidelines

• The screening scope is further narrowed and focused. Highlighting key priorities and weak links, the screening scope is precisely targeted at concealed facilities with higher risks and anti-seepage/isolation facilities in key sites. At the same time, the Guidelines strengthen the distinction from workplace safety management and similar domains, reducing the burden of repetitive screening of above-ground facilities on enterprises. According to preliminary estimates, the number of key sites and key facilities/equipment to be screened by enterprises can be reduced by approximately 30% on average.
• The on-site screening methods are further detailed. Four categories of on-site screening methods are proposed, including document review, visual inspection, leakage detection, and soil and groundwater monitoring. In particular, for concealed facilities, the application requirements for leakage detection are strengthened. A set of relatively mature and economically acceptable reference methods for leakage detection are screened and selected, with their applicable scenarios clearly specified.
• Hazard scenarios and remediation standards are clarified. For 14 categories of key sites and 11 categories of key facilities and equipment, 138 specific hazard scenarios are proposed for enterprises to conduct "checklist-based screening." Corresponding remediation key points are provided for each hazard scenario for enterprises to "select from a menu." In particular, for engineering-based remediation measures, typical models and technical key points are summarized for enterprise reference.

  

Health and Safety

1. < Technical specifications for occupational health surveillance > (GBZ188-2025) (2026-07-01)

The Technical specifications for occupational health surveillance (hereinafter referred to as the Specifications) was issued by the National Health Commission of the People's Republic of China on 20^th August 2025, replacing the GBZ188-2014. It will come into effect on 1^st August 2026. The main revisions to the Specifications are as follows:

1) The Specifications added occupational health monitoring for workers exposed to toluene, bromopropane, iodomethane, ethylene oxide, chloroacetic acid, indium and its compounds, coal tar, coal tar asphalt, petroleum asphalt, β - naphthylamine, metal and its compound dust (tin, iron, antimony, barium and its compounds, etc.), hard metal dust, erionite dust, low temperature, laser, tick-borne encephalitis virus, brucellosis, human immunodeficiency virus, scraping and grinding operations, workers in underground mines who maintain a long-term squatting and kneeling positions, crawling, lateral lying, shoulder support posture , manufacturing workers in long-term wrist repetitive or forced operations, and emergency rescue personnels participating in handling emergencies.

2) The Specifications also added emergency health checks for workers exposed to lead and its inorganic compounds, arsenic and its compounds, fluorine and its inorganic compounds, carbon disulfide, and acrylamide; added occupational health examination at the time of leaving the job for workers exposed to amino and nitro compounds of benzene, phosgene, methylamine, organic fluorine, and dimethyl sulfate.

3) The Specifications removed the individual physical examination conclusions for re-examination and added Appendix E Guidelines for the Preparation of Occupational Health Examination Summary Reports.

2. < Fire safety signs-Part3: Requirements for the installation > (GB13495.3-2026) (2026-08-01)

The Fire safety signs-Part3: Requirements for the installation (hereinafter referred to as the Requirements) was jointly issued by the State Administration for Market Regulation and the National Standards Administration on 28^th January 2026. It will come into effect on 1^st August 2026. The requirements replace the Requirements for the Installation of Fire Safety Signs（GB15630-1995）. The main revision to the Requirements is as follows:

1) The Requirements specify the fire safety signs that shall be installed in distinct parts of various places.

2) The Requirements have improved the distance requirements for setting fire safety signs and have refined the operation and maintenance requirements for fire safety signs.

3) The Requirements have added substrate requirements for fire safety sign products installed indoors and outdoors, minimum size requirements for fire safety signs installed in typical locations, and installation requirements for fire extinguishing equipment signs installed in evacuation routes.

  

Drafted by:
Henry Wang
Feeling Pan
Darrel Chen

Translation Reviewed by:
Kiwi Fu

Approved by:
Paul Shi