In brief

1.The Chinese authorities recently issued three new customs policies, introducing additional requirements for the recording, import, and tariff treatment of the following four (4) types of goods stored in bonded zones or under bonded OEM arrangements in China, which are subject to import/export controls:

• Goods under quota control;
• Goods under trade relief measures;
• Goods subject to suspended trade concessions or tariff cuts; and
• Goods facing retaliatory tariffs.

2. This newsletter analyzes the impact of these policies on certain OEM operations in China and outlines key considerations for adopting an OEM model under the new regulatory framework.

In detail

In the context of ongoing international trade tensions, the Chinese government has implemented trade control measures—including retaliatory tariffs—on certain foreign-origin goods, particularly those from the US and EU.

In April, May, and June 2025, the Chinese authorities, including the General Administration of Customs, issued the following three sets of customs policies to regulate the management and tariff treatment of policy-controlled goods imported under bonded zone or OEM (original equipment manufacturing, known as “processing trade” in China) arrangements.