CHINA Law and Practice Contributed by: Yan Gao, Yilin Wang and Zhuohui Li, Zhong Lun Law Firm
Large-Volume Consumers Large-volume consumers such as data centres may participate in the market through two principal path- ways. The mainstream route requires industrial and commercial users to enter the market directly or through licensed retail companies, with users at 10 kV and above generally required to participate. An emerging alternative is green power direct connection, available in single-user and multi-user modes under the Circular on Promoting the Orderly Development of Green Power Direct Connection (NDRC and NEA, effective 30 May 2025) and the Circular on Promot- ing the Orderly Development of Green Power Direct Connection for Multiple Users, allowing enterprises to receive green power directly from wind and solar facilities via dedicated lines. 2.2 Electricity Imports and Exports China permits the import and export of electricity, though cross-border power trade currently oper- ates primarily under intergovernmental arrangements rather than fully market-based mechanisms. China’s main power import sources are Myanmar, Russia and Laos, while its principal export destinations are Viet- nam, Mongolia, Myanmar and Laos. 2.3 Supply Mix of Electricity According to the Statistical Communiqué on the 2025 National Economic and Social Development published by the National Bureau of Statistics, total electricity generation in 2025 reached 1,057.525 TWh. The supply mix was as follows:
tricity Market Rules (Trial Implementation) (Shandong Provincial NEA, effective April 2026) provide that the aggregate installed capacity of generation enterprises within the same group may not exceed 20% of total market installed capacity, and that affiliated retail companies may not represent users accounting for more than 20% of total provincial market electricity consumption. Entities exceeding either threshold are required to reduce their market share through asset divestiture, transaction segregation or other means. Under the Provisions of the State Council on the Reporting Thresholds for Concentrations of Under- takings (State Council, effective 22 January 2024), a concentration must be notified to and cleared by the anti-monopoly enforcement authority before imple- mentation where: all undertakings participating in the concentration had combined global turnover exceed- ing CNY12 billion in the preceding financial year, and at least two of them each had a turnover in China exceeding CNY800 million; or all participating under- takings had a combined turnover in China exceeding CNY4 billion in the preceding financial year, and at least two of them each had turnover in China exceed- ing CNY800 million. 2.5 Surveillance to Detect Anti-Competitive Behaviour The Anti-Monopoly Regulatory Framework China’s anti-monopoly regulatory framework is based on the Anti-Monopoly Law, which prohibits three cat- egories of conduct: monopoly agreements, abuse of dominant market position, and concentrations of undertakings with anti-competitive effects. Supporting instruments include: • the Provisions on Prohibiting Monopoly Agree- ments (State Administration for Market Regulation or SAMR, effective 1 February 2026); • the Provisions on Prohibiting Abuse of Dominant Market Position (SAMR, effective 15 April 2023); • the Provisions on the Review of Concentrations of Undertakings (SAMR, effective 15 April 2023); • the Provisions of the State Council on the Report- ing Thresholds for Concentrations of Undertak- ings, and the Fair Competition Review Regulations (State Council, effective 1 August 2024).
• thermal power – 632.715 TWh (59.83%); • hydropower – 146.167 TWh (13.82%); • solar power – 117.324 TWh (11.09%); • wind power – 112.792 TWh (10.67%); and • nuclear power – 48.523 TWh (4.59%). 2.4 Market Concentration Limits
There is no national legislation specifically limiting market concentration in the power sector, though mergers and acquisitions in the industry remain sub- ject to the Anti-Monopoly Law. Some provincial authorities have introduced local concentration limits. For example, the Shandong Elec-
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