Shipping 2026

CHINA Law and Practice Contributed by: John Wang, Xu Jun, Song Jia and Zhao Yuxuan, Wang Jing & Co

MARPOL Annex VI (2024 revised). The ship survey organisation conducting the survey shall issue or endorse the relevant certificate accordingly and, within one month of completion, forward the infor - mation specified in this Announcement. • For new vessels: Every Chinese internationally trading ship of 5,000 GT or more delivered on or after 1 August 2025 shall, from the date of delivery, collect energy-consumption data in accordance with MARPOL Annex VI (2024 revised) Appendix IX and report that data to the maritime administration pursuant to the Measures for the Administration of Ship Energy-Consumption Data and Carbon Intensity. • For existing vessels: Every existing Chinese inter - nationally trading vessel of 5,000 GT or more shall revise its Ship Energy Efficiency Management Plan (SEEMP) and obtain verification in accordance with the applicable provisions. From 1 January 2026 onward, such ships shall collect energy-consump - tion data under MARPOL Annex VI (2024 revised) Appendix IX and report the data to the maritime administration in compliance with the Measures for the Administration of Ship Energy-Consumption Data and Carbon Intensity. 9.3 Trade Sanctions PRC law does not incorporate any international trade sanctions. However, if the UN Security Council passes any sanction resolution, the Ministry of Foreign Affairs of the PRC may officially notify relevant governmental authorities for enforcement. In recent years, certain PRC individuals and entities have been sanctioned by some foreign countries in relation to commercial trading, and they have attempt - ed to seek remedy by legal actions. In general terms, the PRC government does not recognise the enforce - ability of any unilateral trade sanctions (including those imposed in the context of the Russia-Ukraine war) imposed by any foreign country. If any such sanc - tion applies discriminatory and restrictive measures against PRC individuals and entities resulting in inter - ference with public interests, the PRC will consider taking corresponding countermeasures. Furthermore, if unjustified extraterritorial foreign trade sanctions are applied against PRC individuals and

entities, they may apply to the commerce department of the State Council for exemption from compliance with a prohibition order. In 2021, China enacted the Anti-foreign Sanctions Law, empowering the Ministry of Foreign Affairs and other relevant authorities to impose sanctions on foreign entities or individuals. In 2025, China further enacted the Provisions on Implementation of the Anti-foreign Sanctions Law, further improving countermeasures, refining some countermeasures procedures, strength - ening the co-ordination among relevant departments and intensifying the implementation of measures. Some sanctions have already been imposed against entities and persons who promoted sanctions against Chinese entities, and who are involved in military sales to Taiwan. 9.4 International Conflict PRC law provides for grounds for failing to perform a contract due to force majeure or hardship. Article 180 of the Civil Code states: “If civil obligations fail to be performed due to force majeure, no civil liability shall be borne. Where the laws provide otherwise, such provisions shall prevail. Force majeure is unforeseeable, unavoidable and “After a contract has been concluded, if the basic con - ditions of the contract have undergone a significant change which is unforeseeable by the parties at the time it was concluded and which does not belong to commercial risks, and it is clearly unfair for the party concerned to continue to perform the contract, the party adversely affected may renegotiate with the oth - er party. If negotiation fails within a reasonable period of time, the parties may request a people’s court or an arbitration agency to modify or rescind the contract. The people’s court or arbitration agency shall, in light of the actual circumstances of the case, amend or rescind the contract under the principle of fairness.” insurmountable objective events.” Article 533 of the Civil Code states:

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