The U.S. just updated its UFLPA list. China's countermeasures followed immediately.
On August 5, 2026, Minister of Commerce Wang Wentao signed Ministry of Commerce Order No. 2, placing 6 U.S. entities on the countermeasure list and prohibiting organizations and individuals within China from engaging in any transactions or cooperation with them.
The order took effect the same day.
According to the annex published by the Ministry of Commerce, the six entities are:
1. Applied DNA Sciences, Inc.
Headquartered in New York, this company specializes in DNA traceability technology, providing traceability solutions for cotton and other agricultural products to the U.S. government and Western buyers. Many of the technical tools used by the U.S. to "screen Xinjiang-related products" reportedly come from this company. Media outlets have directly called it the "tech enforcer" for U.S. Xinjiang-related sanctions.
2. Stratum Reservoir, LLC.
Based in Houston, Texas, this company provides data support for screening and identifying so-called "Xinjiang-related enterprises," serving as a data link in the sanctions chain.
3. Altana Technologies, Inc.
Based in Brooklyn, New York, this company calls itself a "supply chain mapping" enterprise. Customs officials across the U.S. use the company's systems to identify and flag companies with industrial ties to Xinjiang.
4. Responsible Business Alliance (RBA)
A globally recognized business industry alliance. However, on Xinjiang-related issues, the organization has produced numerous supply chain compliance guidelines with pre-set positions, indirectly supporting U.S. sanctions policies and forcing many multinational companies to sever ties with relevant Chinese industries.
5. Verite Group, Inc.
Headquartered in Virginia. According to disclosures from national security authorities, in 2020, the Swiss-based Better Cotton Initiative (BCI) invited Verite to conduct an investigation into "forced labor" in Xinjiang's cotton supply chain. The Verite China project team never conducted on-site investigations; instead, their reports heavily cited fabrications from anti-China organizations, forming illegal evidence through a presumption of guilt.
6. Human Rights in China
A New York-based NGO that has long engaged in anti-China activities, fabricating false information about Xinjiang and lobbying the U.S. Congress and government to promote more restrictive legislation against China.
The countermeasures are based on Articles 3, 4, 6, 9, 10, and 15 of the Anti-Foreign Sanctions Law and its implementing regulations.
Core provision: Organizations and individuals within China are prohibited from engaging in any transactions, cooperation, or other related activities with the above six entities.
Who and what businesses will be affected? Taking the RBA as an example, the impact goes far beyond "not being able to cooperate with the RBA." Professional analysis indicates that Chinese companies may face the following situations:
Interrupted audit cooperation: The RBA's Responsible Minerals Initiative (RMI) has established codes of conduct and audit systems widely used by multinational companies for supplier management. Chinese companies can no longer apply for, renew, or maintain RBA/RMI audit status.
Pressure on international market access: Some multinational companies require RBA audit results as a condition for supplier qualification. Interrupted audit status may affect new order acquisition and fulfillment of existing orders.
Urgent need for alternatives: Companies must adopt other internationally recognized assessment mechanisms. China's own due diligence guidelines for mineral supply chains, which have been recognized by the OECD and LME, can serve as a basis for communicating alternative compliance solutions with clients.
First, audit your supply chain for any ties to these six entities.
If your suppliers, clients, or service providers are associated with any of these six—such as products certified through RBA audits, use of Altana's supply chain systems, or reliance on Applied DNA Sciences' traceability services—you need to immediately reassess your cooperation models.
Second, UFLPA compliance pressure hasn't decreased.
Sanctioning the RBA doesn't mean Chinese companies can relax supply chain traceability requirements. The U.S. UFLPA remains in effect, and importers still need to prove products don't involve Xinjiang-origin materials. Countermeasures address the issue of "striking back when struck," not "the other side has stopped striking you."
Third, find alternatives early.
After RMI audit status is interrupted, proactively communicate with multinational clients. Explain that the suspension of cooperation is due to compliance with Chinese legal requirements, while presenting alternative compliance solutions—using OECD-recognized Chinese standards is far more proactive than waiting for clients to ask you.
These two events on August 5 should be viewed together: the U.S. updated its UFLPA list, and China simultaneously issued countermeasures. Both sides are playing their cards, but goods still need to be shipped and orders still need to be filled. Understanding who's been "blacklisted," who will be affected, and how to pivot—matters far more than just watching the show.
