Other Briefings2025 China Market Access Negative List: Further Openings in Manufacturing, Healthcare, and Entertainment
China’s 2025 Negative List for Market Access marks a further step toward liberalization, cutting down the number of restricted industries and easing private investment restrictions in industries such as manufacturing, healthcare, entertainment, agriculture, pharmaceuticals, retail, and IT. However, it also introduces new restrictions on industries like e-cigarette production, drone manufacturing, online pharmaceutical sales, and non-commercial internet information services. As a key regulatory tool, investors should pay close attention to the changes in the new Negative List to better navigate China’s shifting market landscape.
The National Development and Reform Commission (NDRC), along with the Ministry of Commerce (MOFCOM) and State Administration for Market Regulation (SAMR), has released the 2025 edition of the Market Access Negative List (hereinafter, the 2025 Negative List).
China’s market access negative lists define the industries, sectors, and activities that are either prohibited or subject to government approval for investment by both domestic and foreign entities. This list is distinct from the Negative List for Foreign Investment Access, which outlines prohibitions and restrictions for foreign investors.
Any sector not included in the list is considered fully open to private investment, without the need for prior approval, allowing equal participation from both domestic and foreign market players.
The market access negative list is one of China’s primary policy instruments for liberalizing market entry and improving the business environment. The shortening of the 2025 list reflects a continued effort by Chinese regulators to ease entry barriers and encourage investment in a broader range of industries.
However, despite the overall reduction in the number of restricted areas, some new restrictions have been introduced, tightening regulation in certain fields such as unmanned aerial vehicles, e-cigarette production, online sales of pharmaceuticals and medical devices, and non-commercial internet information services. These additions signal the government’s intent to exercise greater oversight over emerging and sensitive industries, even as it opens others.
2025 Negative List: What has changed?
The 2025 edition of the Market Access Negative List has been further streamlined, reducing the number of restricted fields to 106 across 21 industries, down from 117 in the 2022 edition. Of these, six fields remain entirely prohibited to private investment, while the rest require government approval for market entry.
The list also includes local-level restrictions, which have been trimmed from 36 items to 20, indicating efforts to standardize and reduce regional regulatory barriers.
While the six fully prohibited categories remain largely consistent with previous editions, the first category—“industries explicitly prohibited by laws, regulations, and State Council directives”—refers to a supplementary appendix. The 2025 version of this appendix now contains 153 items, slightly down from 156 in 2022, reflecting a modest narrowing of absolute prohibitions.
| Negative List for Market Access (2025 Edition): Prohibited Items | |
| Prohibited items | Description |
| 1. Prohibited sectors clearly established by laws, regulations, and State Council directives. | 153 items across 15 industries specified in the Appendix of the 2025 Negative List. |
| 2. Products, technologies, processes, equipment, and behaviors that are prohibited or restricted by state industrial policies. | Investment in obsolete items in the Catalogue for the Guidance of Industrial Restructuring is prohibited; restricted items are prohibited from new investment.
It is prohibited to invest in the prohibited items listed in the Provisions on the Administration of Investment in the Automobile Industry. |
| 3. Development activities that do not meet the requirements of the main functional area. | The relevant items listed in the negative list (or prohibited list) of industry access for local national key ecological function zones and the negative list (or prohibited list) of industry access for major agricultural production areas. |
| 4. Financial related businesses in violation of regulations
|
Non-financial institutions and enterprises not engaged in financial activities shall not use the words “bank”, “insurance” (insurance company, insurance asset management company, insurance group company, self-insured company, mutual insurance organization), “securities company”, “futures company”, “fund management company (refers to fund management companies engaged in public fund management business), “trust company”, “financial holding company”, “financial group”, “financial company”, “wealth management”, “equity crowdfunding”, “finance”, “financial leasing”, “Auto finance”, “money brokerage”, “consumer finance”, “financing guarantee”, “pawn”, “credit investigation”, “trading center”, “exchange” and other words related to finance in their registered names and business scope, except as otherwise stipulated by laws, administrative regulations, and the State documents.
Non-financial institutions and enterprises not engaged in financial activities shall, in principle, not use the terms “financial leasing”, “commercial factoring”, “small loan”, “asset management”, “online lending”, “P2P”, “Internet insurance”, “payment”, “foreign exchange (exchange, settlement, and sale of foreign exchange, currency exchange)”, and “fund management (refers to the fund management companies or partnerships engaged in private fund management business. The venture capital industry access shall be implemented in accordance with the relevant provisions of several Opinions of The State Council on Promoting the Sustainable and Healthy Development of Venture Capital (Guofa [2016] No. 53)” and other words related to finance in their registered names and business scope. Where enterprises (including stock enterprises) choose to use the above words in the name and business scope, the market supervision department shall timely inform the financial supervision department of the registration information, and the financial supervision department and the market supervision department shall pay continuous attention to it and list it into the key supervision object. |
| 5. Prohibited internet-related business activities
|
Prohibited measures in the Catalogue of Prohibited and Permitted Access to the Internet Market:
|
| 6. Prohibited news media business activities | Non-public capital shall not engage in the business of news gathering, editing, and broadcasting.
Non-public capital shall not invest in the establishment and operation of news organizations, including but not limited to news agencies, newspapers and periodicals, radio, and television broadcasting organizations, radio and television stations, and Internet news and information collection, compilation, and release service organizations. Non-public capital shall not operate the layout, frequency, channels, columns, and public accounts of news organizations. Non-public capital shall not be engaged in live broadcasting of political, economic, military, diplomatic, major social, cultural, scientific and technological, health, education, sports, and other activities and events related to political direction, public opinion orientation, and value orientation. Non-public capital shall not introduce news released by foreign subjects. Non-public capital shall not hold forum summits and award selection activities in the field of news and public opinion. |
Removed items
Although the finance industry saw the largest reduction in listed items – dropping from nine in the 2022 edition to just three – this does not signal a substantive easing of restrictions. Instead, detailed prohibitions related to the establishment of banks, securities, futures, insurance, and fund institutions, as well as financial guarantee companies, pawnshops, microfinance firms, and credit reporting agencies, have largely been consolidated under the broader provision: “Engaging in Certain Financial Activities Without Approval Is Prohibited.”
However, one restriction has been fully lifted: the requirement that senior executives of certain financial institutions obtain approval before taking office. This change eliminates qualification approval for directors, supervisors, and senior executives of a range of financial entities, including banking and non-banking financial institutions, insurance companies and groups, insurance intermediaries, credit reporting agencies, and bank card clearing institutions.
Beyond finance, several restrictions across manufacturing, agriculture, environmental protection, internet services, and other sectors have also been removed:
Agriculture, fishery, and animal husbandry
- The restriction prohibiting the transfer of land management rights beyond a certain scale without approval (for example, acquisition by industrial or commercial entities) has been removed.
Manufacturing
- Licensing is no longer required to manufacture, renovate, purchase, import, or use ships and fishing vessels for production and operation.
- Licensing requirements for the production, import, or operation of computer information system security products have been lifted (though still required for telecom and radio equipment).
- Restrictions on qualifications for printing special VAT invoices have been removed (but requirements remain for printing bank bills and clearing vouchers).
Water conservancy, environment, and public utilities
- License requirements for the acquisition of productive scrap metals have been lifted (in Yunnan).
- Approval is no longer required for the collection, transportation, and disposal of waste edible oils and fats (in Fujian).
Culture, sports, and entertainment
- Approval is no longer needed to establish radio and TV program production units or TV series (including animation) production units.
Wholesale and retail
- Approval for establishing pharmaceutical wholesale and retail businesses has been removed (business licenses are still required).
Internet market access (prohibited license catalog)
- Approval is no longer required to provide internet information services related to drugs and medical devices.
Health and social work
- Approval is no longer required for medical institutions to use Class I and II radioactive drugs (approval still required for Class III and IV).
Information transmission, software, and IT services
- Trial operation approval for new telecommunications services has been removed.
| Negative List of Market Access (2025 Edition): Restricted Items
(Subject to Approval, Qualification, Licensing Measures, or Requisite Legal Procedures) |
|
| Sector | No. of items (change from 2022) |
| 1. Agricultural, forestry, animal husbandry, and fishery | 9 items (-1) |
| 2. Mining | 1 item |
| 3. Manufacturing | 19 items (-1) |
| 4. Production and supply of electric power, heat, gas, and water | 1 item |
| 5. Construction | 1 item |
| 6. Wholesale and retail | 7 items |
| 7. Transportation, warehousing, and postal services | 7 items |
| 8. Accommodation and catering | 1 item |
| 9. Information transmission, software, and information technology services | 4 items |
| 10. Finance | 3 items (-6) |
| 11. Real estate | 1 item |
| 12. Leasing and business services | 5 items |
| 13. Scientific research and technical services | 6 items (-2) |
| 14. Water, environmental, and public utility management | 5 items |
| 15. Residential services, repairs, and other services | 2 items |
| 16. Education | 1 item |
| 17. Health and social work | 3 items |
| 18. Cultural, sports, and entertainment | 7 items |
| 19. List of Investment Projects approved by the Government that are subject to approval | 10 items |
| 20. Licensing items on the Internet Market Access Prohibited Licensing Director | 5 items (-1) |
| 21. Other | 2 items |
Added items
While the 2025 Negative List eases market access in certain sectors, it also introduces new or tighter restrictions in others, signaling increased regulatory scrutiny in key areas.
For example, in the transportation, warehousing, and postal services sector, investment in civil unmanned aerial vehicles (UAVs)—excluding micro UAVs—now requires certificate approval. This reflects growing concerns around airspace safety, national security, and the rapid proliferation of drone technologies, prompting regulators to assert more control over the sector.
The list also strengthens restrictions on e-cigarette production. It now requires approval for the establishment, division, merger, cancellation, capital construction, or technological upgrades of tobacco product manufacturers – including those producing new tobacco products like e-cigarettes – when expanding production capacity or producing cigarettes and cigars beyond the annual production quota. This continues China’s trend of tightening control over the e-cigarette industry, following measures such as the 2022 ban on flavored vapes and a broader regulatory framework introduced to curb unregulated growth in the sector.
Restrictions have also increased in online pharmaceutical and medical device sales. The 2025 list mandates that entities selling drugs online must either be marketing authorization holders (MAHs) or licensed pharmaceutical distributors with the capacity to ensure product safety. TCM decoction piece manufacturers may only sell their own products and must fulfill MAH responsibilities. MAHs may only sell products for which they hold a valid registration certificate. Entities lacking a retail drug license are prohibited from selling to individuals. For medical devices, only registered or filed holders and licensed distributors are permitted to sell online.
In information services, the list now requires prior approval to provide non-commercial internet information services. This is a significant change from the 2022 edition, where such services were only subject to a filing system. The shift suggests heightened regulatory oversight of online content and service providers, and will make it more cumbersome for companies to set up websites.
Conclusion
The 2025 Negative List reflects China’s continued efforts to streamline regulation and expand opportunities for private investment by reducing the number of restricted sectors. However, the addition of new restrictions in sensitive or rapidly evolving areas – such as drones, e-cigarettes, pharmaceuticals, and internet services – underscores a more nuanced approach, and that while the overall trend is toward market liberalization, regulatory tightening remains in place where public safety, data, or health are concerned. Investors should view the shortened list as a sign of progress, but stay alert to the evolving compliance landscape in high-risk sectors.
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