China RBA Ban: What the 5 August 2026 Decision Means for Global Supply Chains

On 5 August 2026 China named the Responsible Business Alliance (RBA) under its Anti-Foreign Sanctions Law. Companies and individuals in China are now prohibited from transactions, cooperation and other activities with the RBA, the organisation that runs the Responsible Minerals Initiative (RMI) and the Conflict Minerals Reporting Template (CMRT). For any global supply chain with Chinese suppliers, that removes the usual route for collecting conflict minerals data. Your own obligations under US SEC rules and EU regulations have not changed.

What happened in China and the United States

3 August 2026, United States

The United States expanded its UFLPA forced labour import list and added more Chinese producers. Goods linked to a listed producer are, in practice, blocked from entering the United States.

5 August 2026, China

China named the Responsible Business Alliance under its Anti-Foreign Sanctions Law. Companies and individuals in China are prohibited from transactions, cooperation and other activities with it.

Three things to be clear about

1. Your Chinese suppliers currently cannot take part in RMI and RBA processes

The measure prohibits transactions, cooperation and other activities, and that wording has no published guidance and no precedent behind it. Until it is clarified, treat direct engagement with RBA and RMI programmes as unavailable to your Chinese suppliers, and take advice before relying on anything closer to the edge.

2. How far the prohibition reaches has not been defined

There is no published guidance and no precedent. Whether it covers audits only, or extends to routine questionnaires and platform use, is currently unknown. Treat this as unresolved rather than settled in either direction.

3. Your obligations are unchanged

US SEC conflict minerals rules and EU regulations still require you to carry out and disclose supplier due diligence. The duty is to make a reasonable inquiry, apply the OECD framework, and disclose what you found. It is not a duty to run one particular instrument, and it does not require a clean result. Where your usual route is unavailable, you are expected to take reasonable steps to obtain the information another way, and to record what you did.

How to keep your due diligence running

You keep the standards and reporting formats you already use. What changes is how much you need to ask your suppliers for, and what you have when they cannot answer.

Start from what is already known

Every supplier on the platform already has a Twin, so you are not starting from an empty questionnaire. A Twin is a single profile of what is known about that company. It holds adverse media, sanctions and watchlist screening, the supplier’s own public disclosures, records from industry associations and country databases, and anything that supplier has previously provided. A supplier that does not respond is no longer a blank.

Run your framework against it

Screening tells you, requirement by requirement, what is already answered, what is missing, and what needs attention, before you contact anyone. A framework is the set of requirements you measure a supplier against: a standard you already use, such as OECD, IRMA, RMI or RBA, or your own questionnaire. One Twin can be run against several frameworks, and one framework can be mapped to another, so a supplier answers once and that answer serves every framework and customer that needs it. See how this works for CMRT, EMRT and AMRT automation.

Ask only for what is missing

Your request to the supplier drops from a full questionnaire to the specific points that are still open. The supplier provides those points directly to you, as its customer, into its own record. The information is collected for your due diligence process and stays in your process.

The same steps are set out, supplier by supplier, in our China RBA ban briefing.

What you end up with

A completed due diligence record

Origin, smelters and refiners, sourcing policies and the rest of your requirements, in the formats you already use, including CMRT and EMRT. You keep your format and your process.

A forced labour risk view without a single direct question

Built from your own framework together with public and supplier-provided information, and no other sources. The result is a risk level that tells you where to focus. It is a risk level rather than a clearance, and the judgement stays with you.

This is general information and not legal advice. beSirius is independent and does not act on behalf of any government, regulator, or enforcement authority.