According to a 2014 paper by US law professor:

many WTO violations take place in the interstices of law, areas where government officials exercise discretion: whether or not to register a foreign company, to issue it a business license, or to prosecute someone for IP theft. Likewise, China distributes trade regulations to governmental agencies as “internal guidance” (neibu cankao) that should be published under China’s WTO transparency obligations, but in fact never are. The [WTO] dispute settlement system provides a very rough tool by which to reshape a member’s domestic legal system and to monitor its implementation of WTO commitments. A range of violations takes place, either below the radar or without meaningful recourse for investors or manufacturers outside of China.

What's the evidence that China did or does pass such publicly undisclosed trade regulations?

  • By way of potential answers: I recall that during the Covid-handling controversies some Chinese internal documents were leaked. So something similar might have happened to some unpublished/internal trade regulations. Although on a quick google search, I cannot find any stories like that for the latter. Sep 19, 2022 at 5:31

1 Answer 1


“internal guidance” (内部参考) is not used in these. They exist but are for informational purposes only. These kind of actions is usually out of record. So it is unlikely to get any evidence.

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