Post sul blogDecrees 834 and 835 are adding a new layer of complexity to supplier due diligence in China. For companies sourcing from China, collecting the data needed to meet European sustainability regulations is becoming more sensitive — and requires a more careful approach.
What has changed?
In spring 2026, China introduced two new regulations that can affect how supply-chain and ESG information is collected from Chinese suppliers.
Decree 834 – Industrial & Supply Chain Security
Effective from 31 March 2026, Decree 834 restricts certain information-collection activities in China where they are considered to serve foreign legal or regulatory requirements. This can include activities such as ESG audits, forced-labour investigations and extensive supply-chain mapping.
Decree 835 – Countering Extraterritoriality
Effective from 7 April 2026, Decree 835 addresses foreign legislation with extraterritorial reach, including regulations such as the EU’s Corporate Sustainability Due Diligence Directive (CSDDD). It enables Chinese authorities to take countermeasures against organisations complying with certain foreign requirements and allows Chinese companies to seek compensation where compliance causes substantial harm.
The regulations are already being tested in practice. In May 2026, China’s Ministry of Justice issued its first formal ruling under Decree 835 in relation to an investigation by the European Commission.
Why does this matter for companies sourcing from China?
European retailers and manufacturers increasingly need detailed supply-chain evidence to comply with regulations such as EUDR, CSDDD, forced-labour legislation and REACH. This can include information from Tier 1 suppliers through to deeper supply-chain levels, such as geolocation data, supplier questionnaires, audit results and origin information.
The challenge is that some of these standard due-diligence activities may now attract regulatory scrutiny on the Chinese supplier’s side, not just on the side of the European company requesting the information.
Importantly, the new rules do not mean that supply-chain data can no longer be collected in China. Rather, companies need to pay closer attention to what data they request, why they request it, how the request is framed, and how the process is documented.
What should companies do?
For companies sourcing from China, this means taking a more structured and risk-based approach to supplier due diligence. Rather than stopping data collection, companies should assess which information is essential, clearly document the regulatory purpose behind requests, and consider how requests can be made without creating unnecessary risks for suppliers.
At ImpactBuying, we are closely monitoring the developments and their implications for EUDR and other European sustainability regulations. The situation is evolving, and ultimately requires dialogue and alignment between China and the EU. In the meantime, companies should be prepared to adapt their due-diligence approach as the regulatory landscape develops.
