Can I still get an RBA audit of a Chinese factory?
On 5 August 2026 MOFCOM placed the Responsible Business Alliance, Verité Group, Altana Technologies and Applied DNA Sciences on China’s Anti-Foreign Sanctions Law countermeasures list. Organisations in China are prohibited from transacting or cooperating with them, so those programmes cannot be delivered inside China. The underlying factory evidence can still be obtained by other means.
This area changes quickly. The explanation below is written to stay true as the numbers move, and deliberately avoids quoting a rate or threshold that would age badly. Check the official sources at the foot of this page, and confirm with a licensed professional before you rely on it. Last checked 28 August 2026.
This one caught buyers by surprise, because the measure is not aimed at them. MOFCOM Order No. 2 of 2026, announced on 5 August 2026, placed six US entities on the countermeasures list under the Anti-Foreign Sanctions Law, citing their assistance with Xinjiang-related sanctions. Four of the six are infrastructure that Western supply-chain due diligence runs on.
| Listed entity | What buyers use it for |
|---|---|
| Responsible Business Alliance | The Validated Assessment Program (VAP), the Responsible Labour Initiative and the Responsible Minerals Initiative |
| Verité Group, Inc. | Forced-labour assessment methodology and tooling used across the industry |
| Altana Technologies, Inc. | Multi-tier supply-chain mapping |
| Applied DNA Sciences, Inc. | DNA-based material traceability, widely used in cotton |
The prohibition runs on the Chinese side: organisations and individuals in China are barred from engaging in transactions, cooperation and related activities with the listed entities. So the constraint attaches to performance inside China — a Chinese factory participating in an assessment, a Chinese assessor engaged to carry it out — rather than to the clause in your contract or to your own use of these organisations elsewhere.
What this does not change
It does not change what your customer or regulator actually needs to know, which is whether the plant is what it claims to be, who owns it, who works there and where the material came from. That question has never depended on any single programme, and it can still be evidenced directly.
What to do about it
- Check which audit or traceability providers your contracts oblige you to use in China — including through a customer’s standard terms, where the obligation is easy to miss.
- Raise it with the customer rather than quietly substituting something. A documented substitution agreed in advance is defensible; an undisclosed one is not.
- Rebuild the evidence from sources that are not affected: registry records, verified certificates, consented and dated site evidence, and the supplier’s own written answers.
- Record what could not be obtained, and why. A documented gap is a finding; an estimate presented as an assessment is not.
Do not respond by commissioning something covert. The alternative to a programme that cannot be performed is not an undisclosed enquiry — that is the conduct Article 13 of Decree 834 addresses, and it produces a file you could not show to the customer who asked for it.
Countermeasure listings are added, suspended and lifted, and the scope of this one may be clarified. Confirm the current position against the ministry’s own announcements before relying on this page. This is general information, not legal advice.
Want this done rather than explained?
Walk the factory floor without flying — from US$450, Scheduled within 5–10 working days.
Sources
- People’s Daily Online — MOFCOM Order No. 2 of 2026 placing six US entities on the Anti-Foreign Sanctions Law countermeasures list, 5 August 2026
- Ministry of Commerce of the PRC (中华人民共和国商务部)
- Analysis — what the listing means for companies relying on Responsible Business Alliance audits in China
All sources checked 28 August 2026. This page is general information, not legal, tax or customs advice. Requirements vary by product, market and circumstance — confirm your own position before acting.