On December 31, 2025, the Ministry of Finance (MOF) and the Ministry of Industry and Information Technology (MIIT) jointly issued the Opinions of Implementing the Notice on Implementing Domestic Product Standards and Relevant Policies in Government Procurement (hereinafter referred to as “the Opinions”). It provides clarification for the original notice issued by the General Office of the State Council of China, which was published in September 2025.

The original notice provides favored policies for locally manufactured products under certain categories in the government procurement catalogue. The legal basis of the original notice includes but not limited to the Government Procurement Law of China and Foreign Investment Law of China. The stated measures have come into force on January 1 of 2026.

The Opinions emphasize the importance of the measures listed in the original notice, while requiring all stakeholders, especially relevant authorities and regulators to correctly understand and implement the requirements.

Key takeaways of the Opinions include:

-   Significance: the favored policies for locally manufactured products in government procurement is defined as an action to optimize business environment in the country, a long-term national policy that shall ensure the same treatment of foreign invested manufacturers in China with local ones.

-   Requirements on relevant authorities and regulators in implementation: i) accurately define and understand the criteria of "locally manufactured"; ii) MOF and MIIT shall set up reasonable specific requirements after full consultation with domestic and foreign invested enterprises and sector associations. The criteria for products shall vary based on its characteristic and actual development status in China; iii) all demonstration documents for locally manufactured products shall be thoroughly reviewed and audited; iv) necessary supervising measures shall be in place to monitor the criteria set-up and implementation; v) the rights and equal treatment of qualified products and foreign invested manufacturers must be ensured during government procurement. Unfair treatment by any means and forms shall be punished in accordance with relevant laws and regulations. 

-   Supportive and ensuring measures:  i) finance administrators at the regional level shall make practical implementing measures and enhance supervision on review experts and chosen suppliers; ii) optimize internal monitor system, and ensure the requirements in the original notice has been integrated into procurement process; iii) improve cross-department coordination mechanism to ensure government procurement conform with requirements; iv) strengthen communication and feedback channels for suppliers’ comments, and ensure penalties for any types of violation.

For foreign stakeholders, the Opinions further clarifies the purpose of the original notice on locally manufactured product policy in government procurement, and it puts forward more specific requirements for regulators and authorities on different levels to ensure implementation. Such policy will benefit MNCs for foreign entities that have production facilities in China.