China Announces First Investigation under the PRC Sanctions Regime into U.S. Apparel Company PVH

On 24 September 2024, the Unreliable Entity List ("UEL") Working Mechanism Office of China’s Ministry of Commerce issued the first ever investigation notice pursuant to the Provisions on the Unreliable Entity List, citing China’s Foreign Trade Law, National Security Law and the Anti-Foreign Sanctions Law, against U.S. apparel company PVH Group. The announcement marks a departure from the PRC authorities’ past enforcement of the UEL and related sanctions legislation, which have largely focused on Taiwan-related arms sales by non-Chinese entities. This development highlights the delicate balance that multinationals must manoeuvre in supply chain de-risking.

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