Shanghai Circulates Revised Detailed Rules for Trade Policy Compliance to Strengthen WTO Rules Assessment

On June 25, 2026, the General Office of the Shanghai Municipal People’s Government issued the Notice on Forwarding the Detailed Implementation Rules for Trade Policy Compliance Work of Shanghai Municipality as revised by the Municipal Commission of Commerce (the “Detailed Rules”), which took effect upon issuance.

The Detailed Rules clarify that where the municipal and district governments and their departments formulate policies involving trade in goods, trade in services, trade-related intellectual property rights, foreign investment, and other matters, the principle of “who formulates, who assesses” shall apply. Compliance assessment shall be treated as a necessary prerequisite before issuance, and written assessment opinions shall be submitted. For trade policies to be submitted to the executive meeting of the Municipal People’s Government for deliberation, or to be issued or approved by the Municipal People’s Government or the General Office of the Shanghai Municipal People’s Government, the drafting department shall solicit in writing the opinions of the Municipal Commission of Commerce, which shall generally provide feedback within 7 working days and, under special circumstances, generally no later than 15 working days. With respect to written comments from WTO members, the Municipal Commission of Commerce, together with relevant departments, shall provide feedback to the Ministry of Commerce within 15 working days. The Detailed Rules shall take effect as of the date of promulgation, and the 2017 version shall be repealed simultaneously.