PRC regulators have long been cautious and closely monitoring the issuance and trading of cryptocurrencies[2] since the advent of Bitcoin in 2008. Aside from the digital yuan (e-CNY) issued by the People's Bank of China ("PBoC"), China continues to reject cryptocurrencies as legal tender and strictly prohibits their circulation in the onshore market. On September 15, 2021, PBoC, along with nine other governmental, party, and judicial organs, issued the PBoC Circular [2021] No.237 (the "2021 Circular"), clearly prohibiting all onshore "cryptocurrency-related business activities". However, the 2021 Circular was silent on real-world asset ("RWA") tokenization, which has since invited curiosity from market participants.

The current Implementation Regulations of the Drug Administration Law was first enacted in 2002 (the "2002 Regulations"), with minor amendments made in 2016, 2019, and 2024. Following the release of a draft for public comment in 2022 (the "2022 Draft"), which could refer to our article:《汉坤 • 观点 | 《药品管理法实施条例》（修订草案）重点快评》. Since 2002, the Regulations have now been comprehensively revised for the first time. The newly finalized version (the "2026 Regulations") is set to take effect on May 15, 2026. The 2026 Regulations systematically integrates over two decades of regulatory practice with the core principles of the Drug Administration Law. By providing a clear legal basis for several key regulatory mechanisms, the 2026 Regulations aims to establish a more robust and stable institutional framework for the rapidly evolving pharmaceutical industry. This article outlines and analyzes the key highlights of the 2026 Regulations, comparing them against the 2002 version and the 2022 Draft to help companies navigate the new regulatory landscape and understand its practical implications.

As China's outbound investment footprint expands across infrastructure, energy, mining, technology, and real estate, Chinese companies are increasingly navigating complex political, regulatory, and commercial landscapes. While commercial contracts – such as joint-venture agreements – are fundamental, they often provide limited protection when the interference comes from the host State itself.