In December 2025, the Ministry of Finance (MOF) and the Ministry of Industry and Information Technology (MIIT) issued the Opinions on Implementing Domestic Product Standards and Related Policies in Government Procurement. The opinions carry forward the State Council’s earlier notice on domestic product standards and clarify how the rules will apply in practice. Here are the most important points:
Clarifying “Produced in China”
- Products manufactured in bonded zones and other customs special supervision areas are considered “produced in China”.
- Medical devices with a “Domestic Medical Device Registration Certificate” are considered to be “produced in China”, regardless of where core components are sourced.
Welcoming Domestic Products in Foreign Brands
- Procurement criteria should not restrict brands based on the place of the brand’s registration, ownership structure, or investor nationality. In other words, local authorities should not design tenders that favors domestic brands.
- More importantly, the opinions emphasize that non-compliant procurement practices will face enforcement, which points to closer oversight at the local level rather than “guidance only”.
Higher Compliance Expectations for Procurers (indirect impact for suppliers)
- Procurers are required to more carefully verify suppliers’ “domestic production” claims regarding “domestic production”.
- If incorrectly information is being identified, procurers themselves may be held responsible, increasing their compliance and reputational risks.
- As a result, local finance and industry authorities, in some cases together with third-party accounting firms, may conduct on-site checks strictly covering:
- actual production locations,
- where key manufacturing steps are completed,
- and the cost share of domestic components.
AHK Perspectives
Our Business Confidence Survey Report 2025/26 shows that the “Buy China” trend is one of the major regulatory challenges for German companies operating in China, cited by 60% of our member companies, up 3.4 percentage points from the previous year. Against this backdrop, it is encouraging that China has reaffirmed that products meeting the domestic criteria should be treated on an equal footing in government procurement, regardless of brand origin. However, for non-localized companies engaging with domestic product standards, the opinions once again highlight the disadvantages they may encounter.
The opinions also spell out more clearly what actually counts as “produced in China”. Particularly in medical device sector, recognizing a Domestic Medical Device Registration Certificate as the key criterion, rather than requiring full supply-chain localization, might help to ease short-term pressure on German companies to relocate upstream component production to China.
German companies should expect stricter implementation and closer scrutiny. Products marketed as “domestically produced” are likely to face more documentation requests, audits, and site inspections. Good paperwork, traceability in supply chains, and early preparation now really matter. If German companies would like their products to be recognized as domestic we suggest starting by reviewing supply chains and operational footprints, and engaging early with procurement authorities when questions arise.
