U.S.-China Cancer Trial Collaboration: Political and Regulatory Challenges and the Path Forward
Executive Summary
Is U.S.-China cooperation on cancer clinical trials possible, and why have meaningful large-scale efforts failed to take place to date? This paper analyzes the political and regulatory challenges to U.S.-China collaboration and provides policy recommendations for how to expedite the harmonization of cancer clinical trials. It also draws on past instances of U.S.-China public health cooperation for lessons in how to build consensus and mutual trust.
Key Points
- China’s role in global cancer clinical trials has been overlooked because of Beijing’s self-isolation, complex regulatory factors, and an increasingly tense political climate both in the United States and China.
- Clarifying the regulations for and intent behind clinical and genetic data transfer, export, storage, and application are the primary challenges to harmonizing U.S.-China clinical cancer trials. Despite positive initial steps, further progress is needed from Chinese officials to create a more predictable and transparent regulatory environment.
- Political headwinds, including China’s medical sector corruption crackdown, investigations against foreign drug companies in China, the legacy of the United States’ China Initiative, and emerging strategic competition in the biotechnology sector, have degraded trust among scientists and pharmaceutical firms involved in oncology research.
- U.S.-China misperceptions regarding data transfer and usage could be managed through direct working groups, joint frameworks, and the implementation of existing policies such as the U.S.-China Science and Technology Agreement extension and China’s 2023 “Opinions of the State Council on Further Optimizing the Foreign Investment Environment and Intensifying Efforts to Attract Foreign Investment.”
- Bilateral clinical trial collaboration and regulatory harmonization could rapidly scale existing joint oncology research and investments, bring therapies to market faster, form the basis for broader international clinical trial cooperation, and add a stabilizing factor to U.S.-China relations.
Introduction
Although cancer is a disease that afflicts all of humankind, the world’s two great powers have been disproportionately affected by its consequences. Together, the United States and China account for nearly 40% of cancer deaths each year.1 China alone represents 24% of global cancer cases and more than 30% of global deaths.2 Yet to date, the two countries have reached no significant agreement to collaborate on meaningful cancer clinical trials.
U.S.-China joint regulatory harmonization — the alignment of procedures, technical requirements, and certification standards for pharmaceutical products — can expedite cancer research findings and bring therapies to market faster. According to the Bloomberg New Economy International Cancer Coalition, global regulatory harmonization may reduce cancer-related deaths by an estimated 10%–20% annually.3 The breadth and depth of scientific expertise in the United States and China suggest that bilateral regulatory harmonization between the two countries would represent the largest global driver in saving lives and set the tone for direct clinical trial collaboration.
Critical voices in both countries have recognized China’s burgeoning role in advancing cancer research and global public health solutions. Following a long-awaited visit to Beijing during summer 2023, Secretary of State Antony Blinken emphasized the need to work with China on “shared transnational challenges,” including public health.4 When bilateral relations stabilized after President Joe Biden and General Secretary Xi Jinping met in San Francisco in November 2023, the leaders’ stated commitment to restarting people-to-people exchanges led observers to conclude that bilateral scientific exchange would relatedly improve.5 Months later, in his speech commemorating the 45th anniversary of U.S.-China relations, Ambassador Xie Feng highlighted that the two countries must “jointly combat diseases that have long plagued humanity, such as cancer.”6 Finally, China’s readout of the November 2024 meeting between Biden and Xi in Lima, Peru, stressed that the two countries had common interests in improving public health cooperation.7
This paper analyzes the current challenges to U.S.-China cooperation on joint regulatory harmonization on cancer, including hospital agreements, data-sharing protocols, and international clinical trials, through the lenses of data regulation and political limitations. It concludes by assessing recent progress in areas such as investment, data sharing, and science-centered diplomacy while drawing lessons from historical examples of U.S.-China health cooperation for how to better coordinate each country’s interests.
China’s Significance to Global Clinical Trials
China’s model as a prospective partner for countries seeking to accelerate clinical trials due to its rapidly improving infrastructure, cost-effective trials, and scalability has significant potential. Chinese clinical trial patient recruitment occurs two to three times faster than in the United States. Further, drug clinical trial sites in China expanded from only 300 in 2015 to over 1,000 in 2020.8 The Information Technology and Innovation Foundation (ITIF) reported that Chinese cancer trial activity grew more than 146% from 1,040 in 2017 to 2,564 in 2021 — the highest total for any country, and far outpacing the United States.9 The benefits of a large sample size, trial scalability, and robust medical infrastructure have led experts to conclude that China’s direct clinical trial and treatment costs may be up to 30% lower than those in the United States.10
State investments in cancer treatment infrastructure complement China’s success in trial scalability. The Healthy China 2030 Policy, released in 2016, aims to increase the country’s five-year cancer survival rate by 15% over 15 years. The policy has already resulted in the survival rate rising from 30.9% in 2003 to 43.7% in 2022.11 Consequently, China has made massive strides in its treatment regime — the number of oncologists per 1 million people increased from 14 in 2005 to 26 in 2018,12 and the number of specialist oncology hospitals rose from 124 to 146 between 2012 and 2020, 33 of which operate in rural areas.13 Moreover, China’s oncology therapeutics spending has led all emerging markets, reaching $9 billion by 2019.14
Roadblocks, however, persist with respect to China’s engagement in the international public health sphere. China’s efforts to improve its cancer infrastructure notwithstanding, Chinese genotypes are still underrepresented in global cancer research. China continues to trail peer countries in industry trial sponsorship. In 2022, for instance, only 18% of Chinese clinical trials involved foreign companies acting as overseas sponsors, compared to 20%–40% in South Korea, India, and Japan.15 Separately, Chinese companies’ clinical trials tend to stick to their own region, with only 27% of domestic companies using sites outside of China.16 China joined the International Council for Harmonization in 2017 to better accord with international drug trial and approval standards, but foreign companies still struggle with reconciling their trial practices with in-country norms.17
Chinese genotypes are also insufficiently represented in international biobanks, limiting the range of testing and analysis available for the Chinese population in global trials. Although China has heavily invested in its biobanking capacity since the 1990s, research shows that 52% of global genome-wide association studies target populations with European ancestry.18 Thus, the international community could benefit from harnessing the expansive sample sizes and capabilities of Chinese biobanks — roughly 40% of China’s academic hospital biobanks store over 500,000 specimens, well above global averages — while heightening the role of industry-led trial investments in the future.19
For China, greater integration into international cancer clinical trials and global regulatory harmonization efforts would allow it to tap into the research, resources, and knowledge necessary to combat the health challenges associated with its aging population, which bears the brunt of cancer diagnoses. A 2022 study showed that cancer rates among the elderly in China represented 55.8% of total cases and 68.2% of cancer-related deaths, with mortality rates trending upward.20 The proportion of China’s over-60 population surpassed 20% in 2023, making it imperative that Beijing invest in providing advanced cancer care for an increasingly large at-risk population.21 Drawing on more international resources to combat cancer incidence in its aging population would ensure Chinese patients’ access to higher-quality, more versatile treatment options.
Regulatory Barriers
Successful international clinical trials require mediating regulatory challenges between global partners.22 Harmonizing the process by which different countries share standards, data, and goals for product safety, quality, efficacy, and testing is a precondition for making international clinical trials feasible.
The largest existing barrier to U.S.-China cancer clinical trial collaboration is the difference in data-sharing regulations and norms, largely due to the securitization of China’s human genetic resources (HGR) management regime. As a result, the scope of international clinical trials conducted in China has been hamstrung by state security concerns. While China has long closed off international access to its HGR and tightened laws on data exports, recent developments relaxing certain data security reviews and inviting foreign participation in its oncology landscape have created momentum for joint clinical trials.
Human Genetic Resource Restrictions
Genetic data is crucial in cancer clinical trials for recognizing biomarkers and cancer tumor risk factors, understanding tumor molecular profiles, and supporting other areas such as trial design and sample analysis.23 For decades, HGR has been difficult to store, analyze, and apply in China without significant government oversight and approvals, especially for foreign firms.
Under the Interim Measures for Administration of Human Genetic Resources, China’s Ministry of Science and Technology (MOST) has since 1998 forbidden exports of HGR to foreign countries without prior approval. The measures prevent foreign entities from storing, collecting, or transferring HGR unless done so with a Chinese partner or with approval from the Administration of Human Genetic Resources (AHGR) office. This gives Chinese domestic research institutions “exclusive possession rights” over HGR, allowing the state to control existing genetic research and block its use for purposes not aligned with state interests.24 Over the past two decades, the interim measures have been amended to keep pace with the national government’s objective of securitizing emerging technologies.
In 2012, the MOST’s Draft Regulations on HGR underscored the “socially harmful effects” of illicit HGR use and warned against violating relevant privacy statutes.25 By 2016, a new round of HGR Draft Regulations drastically increased fines for offending parties, stipulated guarantees for Chinese researchers’ “significant contributions” to joint international projects, and added criteria for rejecting research collaborations that “jeopardize national security, national interests, or public security.”26 By 2019, penalties increased to $1.44 million, and by 2022, new implementation rules suggested that HGR collection involving more than 500 people, “important genetic families,” or specific areas would trigger a comprehensive security review by the AHGR office.27 Taken together, these regulations have made China one of the most restrictive regulatory environments for HGR data sharing and clinical trial regulations.
Recognizing the obstacles caused by these tightening restrictions and their impact on foreign clinical trials, China has eased some bureaucratic restrictions over the past several years. While sensitive research collaborations will remain exceedingly difficult to pursue, China has introduced measures to reassure foreign entities of its interest in welcoming business and joint scientific research.
The 2022 Draft Implementation Regulations on HGR introduced positive reforms reflecting Beijing’s intentions to reassure international research partners. While the regulations maintain the security review triggered by genome sequencing more than 500 individuals, they also include a provision that aims to ease the pressure on international scientific research by adding a pathway for evaluating non-sensitive research without the notoriously strenuous AHGR review process.28 The regulations were amended again in 2023, refining the scope of foreign parties and more narrowly defining HGR data to exclude clinical data. Now, MOST approval is only required for collection activities involving 3,000 cases or more, with possible exemptions for international clinical trials.29 These guidelines reduced the workload for MOST approval of relevant HGR cases by over 40%.30
The significance of these changes cannot be overstated. By marking boundaries between clinical data and general HGR collection while adding clinical trial review exemptions, the regulations and their associated security reviews will become much easier for cancer clinical trial operators to navigate in the coming years.
Cross-Border Data Export: Challenges and Progress
The restriction of HGR collection, storage, and export by the MOST covers only one facet of China’s complex regulatory framework for joint clinical trials, especially those regarding cancer. Another regulator, the Cyberspace Administration of China (CAC), has also taken a more active role in the scientific data-sharing landscape in recent years. The CAC is best known as the chief implementation body of China’s big tech crackdown, but it has also tightened the operating environment for clinical trials through the lens of outbound data transfers.
Passed in 2021, the Personal Information Protection Law (PIPL) requires specific and informed consent from individuals whose personal information is handled, collected, or exported. As researchers have pointed out, the PIPL does not provide exemptions for the use or re-use of medical health data, which must abide by the same restrictions as any other sensitive data.31 Given that many important breakthroughs hinge on large-scale, sensitive medical data collection, the PIPL presents unique challenges for researchers. For instance, to facilitate cross-border data transfers, the PIPL stipulates that entities must obtain a recognized data protection certification, pass a CAC data security assessment, or sign a CAC-approved standard contract with overseas data recipients, all while complying with data localization requirements.32
The PIPL’s restrictions are supplemented by specific CAC statutes. Pursuant to the PIPL, the 2022 Outbound Measures for Data Assessment detail that data handlers managing and exporting the sensitive personal information of more than 10,000 people are subject to intensive security review. It also broadens the definition of impacted entities to both leave room for discretion on the part of the CAC as well as those that export public health data, including hospitals, biobanks, and other researchers.33 Even though security reviews must be completed within 57 days of an application, companies often wait months for feedback or additional information from the CAC. The measures have thus significantly hampered researchers’ ability to conduct international clinical trials while forcing biopharmaceutical companies into a precarious position when localizing data. The Financial Times reported in January 2024 that only one-quarter of CAC outbound data export applications had been approved since the introduction of the measures.34
These changes have made it extremely difficult for scientists and companies to work on large-scale projects such as clinical trials, let alone share data. As biological samples collected from clinical trials can be classified as “sensitive personal data,” the CAC’s growing role in health data regulation has presented new challenges for researchers.35 Yet, the CAC has noted the challenges experienced by international partners pursuing genomic data research. The Outbound Measure Draft Rules proposed in September 2023 state that data under the broad category of “academic cooperation” will no longer require a security review.36 Furthermore, the preapproval requirements of a CAC security assessment, standard contract, or personal information certification will not be necessary in other low-sensitivity categories.
Although it remains uncertain how the relaxation of these rules will impact clinical trials, analysts have suggested that the Outbound Measure Draft Rules may furnish “substance behind [China’s] commitment” to foreign partners and businesses while reducing regulatory risks for data flows.37 In March 2024, the CAC released updates to its outbound data transfer regime, which notably exempts security assessments for exporters of the non-sensitive data of 100,000 individuals (and fewer than 1 million) with a standard contract or personal information certification, representing considerable progress.38 In January 2025, the CAC released draft rules on personal data export that clarified certain reviews for companies transferring health information and biometric data, considered “sensitive” data categories.39 These reforms project positively, providing more stable and predictable regulatory mechanisms for scientists and pharmaceutical companies that have struggled to conduct academic studies or scout out clinical trial opportunities.
National Biotechnology Securitization Measures
Naturally, regulatory changes by the MOST and the CAC were not made in a vacuum; they followed protectionist national rhetoric and changing laws, largely corresponding with General Secretary Xi Jinping assuming leadership in 2012. In 2015, the passage of the National Security Law reserved the state’s power to “improve the handling of public health, public safety, and other types of outbreaks that influence national security and social stability,” marking China’s first law to explicitly link public health and biosecurity to national security.40 The following year, the State Council released the Guiding Opinions on the Application and Development of Big Data in Healthcare, which labeled biomedical data an “important, foundational strategic state resource.”41 Finally, in 2020, the Biosecurity Law codified China’s full sovereignty over HGR and added a new reporting mechanism to the MOST’s HGR export approval process.42
These changes correspond with the popularization of Xi Jinping’s concept of Holistic National Security, first introduced at a 2014 Politburo Study Session. This concept espouses a “vision of policy that views all fields as interrelated and inseparable.” In its latest interpretations, it has centered public health as a “major risk” to national security and social stability, positioning HGR as more of a state asset than a tool for scientific research.43
Beijing has consequently put HGR sovereignty into practice, keeping foreign technologies and interests sidelined in favor of domestic alternatives. As mandated by the updated HGR Draft Regulations, China’s “national genetic survey” began in summer 2023, tasking provincial authorities with compiling regional genetic and population data before submitting it to the MOST for domestic storage. This has largely been interpreted as China “stockpiling” its resources to ensure domestic stability and national security, excluding foreign firms from cultivating China’s trove of health data.44
These actions, taken in lockstep with the elevation of biotechnology and biopharmaceuticals as critical technologies for independent innovation in the Made in China 2025 industrial policy and sector-specific Five-Year Plans, harm regulatory harmonization for cancer clinical trials. Such policies allow Beijing to overtly subsidize and prioritize domestic players while linking life sciences development to state power and national security.45 According to the ITIF, China’s 14th Five-Year Plan focuses on moving from “incremental to more radical innovations” in biotechnology to become globally competitive.46
Premier Li Qiang’s 2024 Work Report also embodies this inconsistent logic. The report commits to lowering market access barriers for foreign firms in healthcare while simultaneously declaring that Beijing will “consolidate and enhance its leading position” in innovative drugs and expand domestic support for the life sciences sector.47
In sum, the gradual tightening of national security, data transmission procedures, and HGR ownership rights, in addition to overt privileging of domestically developed technologies, has made performing joint cancer clinical trials in China increasingly difficult. Without efficient HGR collection or international transfer mechanisms, researchers will inevitably struggle to tap into China’s uniquely vast resources or produce optimal results. Recent regulatory progress on the margins, though heartening, is only the first step needed to jumpstart clinical trial success in China.
Steady Improvements and New Momentum
Since the end of 2022, Chinese officials have acknowledged the harm caused by the over-securitization of HGR export and data transmission. Consequently, authorities have taken successive steps to reform relevant bureaucracies and explicitly welcome foreign partners back into the sector.
Arguably the most important reform to China’s genetic resource regime arrived in March 2024, when the HGR management portfolio was transferred to the National Health Commission (NHC).48 This simple bureaucratic measure could impact how HGR is supervised in the future. Possible reforms include raising HGR security review thresholds from 3,000 to 10,000 subjects, clarifying the definition of foreign entities subject to administrative review, optimizing the application processes, and revising “overlapping and contradictory” statutes.49
If such changes are pursued by the NHC, the conditions for data sharing, clinical trials, and foreign investment in the pharmaceutical sector would immediately improve, making China more attractive for international clinical trials. While far from final, the NHC’s ongoing reform discussions reflect Beijing’s commitment to shaping the future direction of international collaboration in the life sciences, biotechnology, and pharmaceutical sectors. The regulatory reforms mentioned above have already resulted in positive signs. In January 2023, a joint cancer research project between hospitals in Beijing and Amsterdam marked the first compliant foreign data transfer.50 This move was as much a political signal as it was a regulatory one. With cancer research clearly marked by Beijing as a priority area for data transfer priority and compliance, the approval of more advanced clinical trials may soon follow.
Other political signals have come from top leadership at the NHC. In November 2023, an updated action plan for Healthy China 2030 emphasized the importance of improving comprehensive clinical evaluation of cancer therapies, accelerating the registration of foreign cancer pharmaceuticals, and unblocking import channels for severely needed overseas drugs.51 In September 2024, a joint circular from the NHC, the National Medical Products Administration (NMPA), and the Ministry of Commerce stated that foreign investors could establish fully owned hospitals in select cities and allowed foreign companies to research human stem cell treatments and technologies.52
Finally, China has recognized the importance of global clinical trials by identifying foreign biotechnology and scientific research as key drivers of its economic growth. Led by Premier Li, the State Council introduced the “Opinions on Further Optimizing the Foreign Investment Environment and Intensifying Efforts to Attract Foreign Investment” — known as the 24 measures — in August 2023, aimed at encouraging foreign investment, pledging to fast-track cross-border data security reviews for “qualified” businesses.53 The Third Plenum’s decision document in July 2024 similarly called for opening up the medical sector for foreign investment and trade.54
The States Council’s 24 measures encourage foreign enterprises to set up local research centers and collaborate on national science and technology projects. Most important for cancer clinical trials is the focus on expediting approvals for foreign-invested enterprises’ biopharmaceutical drug listings and commissioning foreign-led clinical trials. The measures were buttressed by follow-up consultations and notices from the State Council on increasing foreign investment in March 2024.55 The same month, Minister of Commerce Wang Wentao held a roundtable with foreign pharmaceutical company representatives to encourage innovation cooperation and exchange views on industry development.56 While details on how to execute the 24 measures have been vague, Beijing is incrementally easing bureaucratic processes and providing regulatory support to attract clinical trials and foreign biotechnology investment.
Beijing has also invited relevant U.S. participation in cancer cooperation through key diplomatic and commercial channels. In June 2024, the National Committee on U.S.-China Relations led the U.S.-China Forum on Cancer Prevention and Treatment with Peking University, focusing on clinical services.57 In September 2024, former Commerce Undersecretary for International Trade Marisa Lago held a ministerial meeting with her counterpart, Vice Minister Wang Shouwen, during which they reviewed collaboration on cross-border data flows and healthcare to improve outcomes for Chinese patients.58
Most importantly, representatives from the NHC traveled to Washington in September 2024 to visit the Department of Health and Human Services and discuss deepening exchange on cancer prevention and treatment.59 This marked the first NHC ministerial visit to the United States since 2017, signaling the return of science-centered exchanges and dialogues to advance joint clinical trial priorities.
A Tense Political Climate
Aside from the complexity of regulations and technical challenges, U.S.-China cancer collaboration is hindered by a challenging political climate in both countries that discourages scientist-to-scientist relationships and scholarly exchange. Voices within the U.S. scientific community persist in advocating for joint cancer research and limited forms of cooperation by various U.S. and Chinese government bodies. But closer collaboration on cancer trials has been limited by intensifying technology competition, rising security concerns, and industry anticorruption probes.
The United States: Courts, Congress, and Technology Controls
In the United States, bilateral cancer research cooperation has been impeded by a confluence of several factors, including the China Initiative, legislative scrutiny over joint research benefits, and executive actions impacting Chinese firms and U.S.-China data transfers.
Created by the Department of Justice in 2018, the China Initiative was designed to combat Chinese economic espionage within U.S. research institutions, industry, and academia, where the department alleges that over 60% of economic espionage and trade theft cases contain a nexus to China.60 Despite being launched to target a tangible and critical weak point within the U.S. national security ecosystem, observers have suggested that the initiative disproportionately targeted and profiled ethnically Chinese scientists, often without sufficient evidence. By 2021, an MIT Technology Review database found that only 25% of cases filed under the China Initiative involved clear violations of the U.S. Economic Espionage Act, while the majority concerned matters of “ambiguous claims of research integrity.” This led numerous academics, advocacy organizations, and science associations to question the initiative’s intentions.61
The China Initiative was formally terminated in February 2022, but its reverberations within the scientific community induced a chilling effect across U.S.-based research with Chinese counterparts.62 A study found that since 2019, U.S.-based scientists have been reluctant to start or continue collaborations with Chinese institutions, and those of Chinese heritage disproportionately experience greater government scrutiny of their work.63 An additional study involving Chinese-American scientists found that over 72% of respondents do not feel safe in their academic research, and 86% perceive it has become more difficult to recruit top international students.64 In September 2024, a bill that would revive the China Initiative, the Protect America’s Innovation and Economic Security from CCP Act of 2024, passed the House of Representatives.65
The China Initiative succeeded in removing and penalizing scientists who conducted unauthorized research-sharing with Chinese institutions and failed to disclose their ongoing affiliations.66 Such cases should not be discounted when building national security protocols for international research collaborations. However, as described above, the impacts of the program have been widely felt across the U.S. scientific community and, in some instances, risk undermining U.S. competitiveness and innovation. One study assessed that the loss of trust within U.S.-China scientist-to-scientist relationships meant lower productivity, less scientific risk-taking, and an overall hesitation to pursue joint projects.67
While the National Institutes of Health (NIH) is taking steps to improve relationships with colleagues of Asian heritage affected by the initiative, some researchers have said that the effects of scrutiny may be “irreversible.” Consequently, these researchers contend, the China Initiative may have weakened U.S. scientific competitiveness on the global stage.68 There is some data to support this claim. In the last several years, leading scientists have even left the United States to establish laboratories in China after perceiving unwarranted investigations of their work.69 The return of the China Initiative would likely precipitate additional challenges for U.S. scientists seeking to collaborate with Chinese partners, especially those of Asian heritage.
Alarms about biomedical cooperation with China also extend to Capitol Hill. Congress, citing national security risks, appears poised to take actions that could further complicate U.S.-China scientific cooperation in life sciences research, impacting cancer clinical trials. When former President Joe Biden’s executive order in summer 2023 banned U.S. outbound investment in Chinese critical technologies such as AI, quantum computing, and advanced semiconductors, critics argued that the measures inadequately addressed China’s weaponization of emerging technologies, including biotechnology. In the aftermath, former Senator Marco Rubio (now secretary of state) and Rep. Michael McCaul pointed out the order’s lack of attention to Chinese biotechnology and other critical industries. Rubio had previously proposed legislation in 2021 that would outright ban NIH funding for Chinese government-affiliated entities and require corporate filings with the U.S. Committee on Foreign Investment for HGR transfers, including those with China.70
Similar measures have been advanced by the Select Committee on the Chinese Communist Party. In a December 2023 report, committee members called on President Biden and the U.S. State Department to develop “expanded multilateral controls” on Chinese biotechnology and place Chinese companies that collect U.S. genomic data on the Commerce Department’s Entity List.71 The committee later uncovered evidence that several major U.S. biopharmaceutical companies had conducted clinical trials alongside the People’s Liberation Army (PLA), eliciting industry concerns.72 In January 2025, the committee requested that the Commerce Department update regulations to require U.S. entities to obtain licenses before conducting clinical trials with PLA-affiliated hospitals.73 Tightening regulations on these exchanges and transactions is not solely the ambit of Republicans, either. Ranking Member Rep. Raja Krishnamoorthi also introduced the BIOSECURE Act in January 2024, which would restrict federally funded medical providers from using Chinese “biotech companies of concern,” including BGI Group, WuXi AppTec, and their subsidiaries.74 Although the BIOSECURE Act did not become law, its potential ramifications have led pharmaceutical companies to find alternative partners and suppliers outside of China.75
The Biden administration followed suit with its own concrete steps to deter scientific ties with Beijing, particularly concerning genetic data and biotechnology. In September 2022, former National Security Advisor Jake Sullivan called biotechnology, inclusive of life sciences research, a “force multiplier” and a “national security imperative.”76 The United States has accordingly taken steps to improve domestic biotechnology manufacturing capabilities while removing China’s largest international firms from the bilateral research equation. In spring 2023, several subsidiaries of Chinese genetics giant BGI were added to the Entity List.77 Another Biden executive order prevents the large-scale transfer of Americans’ personal data (e.g., genetic and health data), and this was supplemented with a final rule in December 2024 — primarily drawn up to prevent illicit Chinese access to American genetic and health data, according to administration officials.78 In the final days of the Biden administration, the Commerce Department also instituted an interim final rule implementing new controls preventing the export of certain mass spectrometers and cytometers — which are used to generate “high-content biological data” — to countries of concern such as China.79
Many of these actions are based on legitimate U.S. security interests and extend beyond the field of oncology. Biotechnology has long been identified as dual-use with military applications and as a tool for state surveillance.80 BGI has collected thousands of prenatal genetic samples from women overseas while jointly researching the same with the PLA.81 WuXi AppTec has been accused of transferring U.S. clients’ data back to China without consent.82 Recent reports from the U.S.-China Economic and Security Review Commission and the U.S. State Department International Advisory Board have outlined how bulk data transfers to China endanger intellectual property (IP), harming national competitiveness.83 Most controversially, unanswered questions regarding the spread of COVID-19 in China — and Beijing’s lack of cooperation in both pandemic prevention and origin tracing — have inspired fierce skepticism and serious questions about Beijing’s trustworthiness as a public health partner from Congress, the intelligence community, and elsewhere.84
All told, the political and regulatory environment regarding U.S.-China cancer collaboration presents a paradox for observers: concerns and precautions about bilateral scientific exchange are vital to protecting U.S. national security. But at the same time, joint cancer research efforts are still in the United States’ national interest.85
Washington should tread carefully in certain scientific partnerships with China — it will take time to restore trust and transparency. These precautions notwithstanding, officials can create strong foundations for oncology research that can save American lives and afflicted patients worldwide through assured partnerships and limited data-sharing mechanisms. For instance, China’s potential inclusion in Project Orbis, a framework created by the U.S. Food and Drug Administration (FDA), would include only clinical trial data transmission and not genetic data transmission, assuaging security concerns.86 As underscored by the extension of the U.S.-China Science and Technology Agreement in December 2024, American national security and bilateral scientific exchange need not be mutually exclusive.
Going forward, resuming U.S. science-centered diplomacy and knowledge exchanges in oncology at scale could serve as a successful tool in retaining foreign talent, demonstrating regulatory transparency, and jumpstarting innovation.
China: State Securitization and Another Industry Crackdown?
While Washington has tightened areas of permissible oncology cooperation with China, Beijing has taken troubling steps that degrade the environment for joint clinical trial projects through industry crackdowns and the consolidation of state biotechnology strategies. In 2022, China’s Ministry of State Security cracked down on foreign due diligence and consulting firms operating in the country, including Mintz Group and Bain & Company. Mintz Group was fined $1.5 million for “unapproved work.”87 Consulting firms have since been described by the ministry as “a cover” to steal state secrets and undermine national security.88
Traditionally, biopharmaceutical firms and other medical research institutions have relied on firms like Mintz Group and Bain & Company, as well as factory inspectors, to evaluate Chinese partners and identify areas of risk. In April 2024, reports emerged that Western pharmaceutical inspectors were refusing to visit China out of fear of arrest; FDA advisors have allegedly been turned away from factory inspections more regularly since the pandemic.89 If these firms and agencies are unable to operate in a relatively open environment, it will be difficult for joint clinical trials to operate with the requisite transparency, scaring away foreign partners.
Such scrutiny has even extended to pharmaceutical firms. In 2023, a Japanese executive from Astellas Pharma was detained by authorities on suspicions of espionage (the executive was later indicted in August 2024).90 In September 2024, AstraZeneca confirmed that several of its Chinese employees had been detained by state security authorities for reportedly bringing unapproved cancer treatments into the country; the company confirmed its China president was under investigation a month later.91 While the reasoning behind executive detentions varies on a case-by-case basis and details are generally not made public, such punitive actions seriously harm the conditions for foreign pharmaceutical companies and multinationals operating in China, which are increasingly alarmed with the safety of their in-country staff.
Biotechnology competition is also seemingly on Beijing’s mind as Washington begins reviewing its trade ties with China. Just hours after President Trump’s “opening salvo” of 10% broad-based tariffs on Chinese imports went into effect on February 4, 2025, China responded by placing U.S. biotechnology firm Illumina — a world-leading genome sequencing technology provider — on its unreliable entities list.92 Analysts predict that the pharmaceutical industry could be China’s next retaliatory target should U.S.-China trade negotiations break down.93 If competition does intensify, foreign pharmaceutical companies may face even more challenging market conditions in China.
Further complicating the situation is the Chinese medical sector’s ongoing antigraft campaign. Beginning in August 2023, nationwide crackdowns on the healthcare sector have resulted in at least 52,000 medical corruption cases, including the punishment of more than 350 prominent figures in the healthcare industry, according to the National Supervisory Commission.94 In fact, the 2024 and 2025 Central Commission for Discipline Inspection communiqués stated that it was “necessary to deepen the rectification of corruption in areas such as medicine,” where “political and economic issues are intertwined.”95 In July 2024, the NHC and fourteen other departments issued the “Key Points for Correcting Unfair Practices in the Field of Pharmaceutical Purchase and Marketing and Medical Services in 2024.” The directive calls for targeting commercial bribery violations and investigating incidents of illegal kickbacks under the guise of conferences and drug trial promotions.96
While, at face value, this anticorruption campaign may not come at the expense of advancing joint clinical trials — and may help eliminate deep-rooted unethical industry practices — hospitals will face serious challenges in taking on new partnerships with foreign institutions due to ongoing probes.97 In fact, some reports have shown that Chinese physicians are now hesitant to prescribe imported drugs or attend international industry conferences as a result of the pressure campaign.98 As of late, physicians have gone so far as to express public frustration regarding their limited access to foreign therapies and the questionable quality of domestic substitutes, prompting a government response.99 These political headwinds damage efforts to attract foreign biopharmaceutical investment and oncology research.
Thus, while Beijing has taken small steps to make foreign firms more comfortable by encouraging overseas pharmaceutical investment, improving cross-border data mechanisms, and lowering tariffs on foreign cancer therapies, further progress is needed to facilitate a more stable and predictable environment for end-to-end U.S.-China scientific cooperation in cancer research.100 Aside from meeting the foundational challenge of regulatory harmonization, political challenges pose the next most significant obstacle preventing scientists, companies, and institutions from forging and maintaining the relationships necessary for conducting U.S.-China cancer clinical trials.
Recommendations and the Path Forward
The U.S.-China Science and Technology Agreement as a Springboard
Despite the serious political challenges embedded in U.S.-China joint oncology clinical trials and corresponding regulatory harmonization, the five-year extension of the U.S.-China Science and Technology Agreement (USCSTA) in December 2024 underscores how government-to-government research arrangements can help scientists pursue cutting-edge work while alleviating significant political pressures.
The USCSTA was signed in 1979 as a mechanism to address global challenges in health, energy, and climate change, ultimately resulting in nearly 100 different protocols.101 After more than four decades of continuous operation, criticism of the agreement emerged in recent years over concerns regarding forced technological transfer, IP theft, and the integration of science and technology objectives into China’s grand strategy.102 Consequently, the Biden administration declined to pursue a wholesale refresh of the USCSTA, which was extended for only six-month periods in August 2023 and March 2024. For months, the two countries were unable to find a way forward, with U.S. renegotiations prioritizing guardrails to prevent joint research efforts from benefitting Chinese civil-military fusion.
Yet, the U.S. State Department announced in December 2024 that it had worked with China to amend and extend the USCSTA for a five-year term.103 The extension’s language is limited to “basic research” and does not cover critical and emerging technologies, unlike previous iterations. The amended agreement also includes new carveouts for IP protections, researcher safety, and data reciprocity, thereby safeguarding U.S. national interests and addressing some of the concerns raised by lawmakers.104
The adjustments to the USCSTA demonstrate how both national security interests and science diplomacy can be supported during a fraught moment in U.S.-China relations. Further, they can ultimately symbolize momentum for bilateral cancer research. Beyond spurring institutional cooperation, the USCSTA has been invaluable in shaping a political climate that welcomes and retains top Chinese STEM talent in the United States. An estimated 42.5% of international graduate students are from China, and approximately 90% of Chinese STEM PhDs remained in the United States following graduation between 2000 and 2015.105 The agreement has additionally provided the United States with large pools of research subjects and longitudinal health studies deemed instrumental for clinical oncology research. Even more critically, the USCSTA has driven specific cancer research projects, including the U.S.-China Program for Biomedical Research Cooperation through the National Cancer Institute and the National Natural Science Foundation of China.106
In its current form, the USCSTA will make some forms of government-sponsored, security-intensive oncology research impossible (e.g., generative AI-assisted genomic research), but it nevertheless remains a springboard for existing exchanges and new ideas in U.S.-China cancer collaboration.107 As demonstrated by the impacts of the China Initiative, researchers exercise greater caution when pursuing international research experiments in the absence of state support. The USCSTA extension therefore provides a safety net for U.S.-China oncology research to develop and deepen under assured circumstances.108
Misperceptions and Recommendations
To overcome the weighty regulatory and political challenges to joint clinical trials, several modest, incremental steps could be implemented to reduce misunderstandings, clarify intentions, and establish protocols to prevent data misuse.
The largest risk identified by both sides in allowing China to fully integrate into U.S.-led clinical trial networks is the issue of data transfer. This can be solved through pointed and direct communication that addresses mutual concerns, especially as major stakeholders have expressed alarm about the potential weaponization of genetic data to target their respective populations. A straightforward channel to clarify these aspersions would be to initiate a biosecurity dialogue, similar to the U.S.-China AI dialogue created by former National Security Advisor Sullivan and Foreign Minister Wang Yi.109 Establishing a common framework for genetic data use and small-scale confidence-building measures could clarify mutual suspicions regarding data transfers in cancer clinical trials.
A second challenge will be addressing physical safety concerns of scientists involved in U.S.-China clinical trials. China has condemned perceived harassment of its students and scientists entering the United States in recent years, while the United States remains wary of how its citizens are subject to the “arbitrary enforcement of local laws” when conducting fieldwork in China.110 Providing mutual, explicit, and repeated assurances on the fair treatment of each country’s citizens should help restore stability and normalcy to basic scientific cooperation and bilateral cancer research. The renewal of the USCSTA and its amended focus on researcher safety are constructive developments toward restoring normal scientific exchanges, but continued emphasis on ensuring researchers’ fair access to resources will remain vital to stabilizing research cooperation.111
To manage additional misperceptions, the United States and China should take actionable measures to ensure reciprocal market access for innovative cancer therapies. While China has committed to accelerating drug registrations and approvals for foreign cancer drugs by becoming a member of the International Council for Harmonization, introducing its 24 measures, and implementing the Healthy China 2030 plan, the rollout of these policies has been slow and uneven. Conversely, the United States requires exceedingly stringent standards for foreign cancer drugs to enter its market, often taking years, if not decades, for approval. In one instance, in October 2023, the novel Chinese antibody drug toripalimab was approved only after robust testing and certification in 2018 by the Chinese NMPA.112 Meanwhile, studies have shown that China has been relatively quick to approve FDA-supported cancer therapies.113 While both sides have different drug approval systems and should follow evidence- and science-based protocols, accelerating the mutual market entry of these drugs may prove crucial for improving clinical trial coordination.
The Untold Benefits of Cooperation: A Retrospective and New Dynamics
Few studies quantify the benefits of harmonizing U.S.-China clinical trials, but analysis of only a few key data points reveals the potential fruits of full integration. According to research published in the Harvard Business Review, full U.S.-China clinical trial harmonization for enzalutamide, a prostate cancer therapy, could save up to 500,000 patient life years — the largest impact of any potential bilateral harmonization.114 In reality, enzalutamide was approved for use in China seven years after FDA approval. As the Asia Society Policy Institute has shown, U.S.-China clinical trial harmonization and mutual market acceptance could reduce a cancer drug’s life cycle of trials, testing, manufacturing, and approval from 10–15 to 2–3 years.115
From a business perspective, bilateral cancer clinical trial harmonization could help U.S. and foreign biotechnology venture funding in China recover from major lows in 2022 and 2023 and return to the $19.3 billion seen in 2021.116 Given the flight of foreign capital and stock market instability in China through 2024, the country could greatly benefit from a new round of biotechnology investment and oncology infrastructure scaling. On the direct investment side, several foreign firms, such as AstraZeneca, Eli Lilly, Bayer, Pfizer, Sanofi, Moderna, and Bristol Myers Squibb, have expressed interest in expanding their operations in China. Opening comprehensive cancer clinical trial pathways would be a tangible step in drumming up even greater investment interest from these stakeholders.117
U.S.-China cancer clinical trial collaboration may also stabilize elements of the two countries’ strained diplomatic relationship while opening new opportunities to address other shared challenges. There is significant precedent for joint public health projects that build consensus and trust between the United States and China. U.S.-China collaboration in combating the HIV/AIDS epidemic in China from 2002 to 2018 not only drastically improved health outcomes for individuals living with HIV but also set forth a flurry of U.S.-China public health cooperation projects in other fields. HIV/AIDS cooperation enhanced scientific exchanges and forced China to scale up investment into its healthcare system, with state expenditures on HIV prevention and control growing nearly 10% annually during the period.118
Further, the HIV/AIDS collaboration created room for international organizations, NGOs, and private stakeholders to play a larger role in health diplomacy through grassroots educational campaigns, prevention, and testing efforts. Work completed by organizations like UNAIDS, the Clinton Foundation, the Gates-China AIDS Project, and the Global Fund persuaded Premier Li Keqiang to raise funding for China’s own community-based AIDS prevention organizations.119 Insights generated by U.S. doctors in China during the collaboration were also used as treatment templates for HIV/AIDS in several African countries.
Lasting relationships and productive exchanges between U.S. and Chinese health officials during the HIV/AIDS collaboration ultimately allowed the two countries to “present a united front” against the 2014 Ebola outbreak in Sierra Leone.120 High-level meetings between U.S. and Chinese officials ignited joint disease control efforts. Personnel from both countries deployed mobile labs to fight the outbreak, while diplomatic staff communicated on disease developments and medical supply distribution.121 This narrow and targeted collaboration on a transnational public health threat successfully controlled the outbreak and later paved the way for U.S.-China joint efforts to help establish the Africa Centres for Disease Control and Prevention.122
If executed properly, U.S.-China cancer clinical trial collaborations may yield benefits for public health officials, civil society, and cancer patients both inside and outside of China. In the U.S.-China HIV/AIDS and Ebola collaborations, a spirit of shared purpose galvanized efforts from the grassroots up, with scientists and agencies sharing relevant data and resources to achieve the best patient outcomes.
Beyond helping patients, effective U.S.-China cancer clinical trials could serve as a model to alleviate data-sharing concerns and engender more productive bilateral relations across a variety of global public goods, such as climate change, AI safety, food security, and basic scientific exchange. On a more fundamental level, collaboration may prove each country’s role as a responsible international stakeholder and improve global perceptions of the U.S.-China relationship in certain arenas. For instance, even at the height of the Cold War, the United States and the Soviet Union collaborated on smallpox vaccine distribution to developing countries, demonstrating that even geopolitical archrivals can stand “shoulder-to-shoulder against disease.”
Finally, and most importantly, full U.S.-China cancer clinical trial integration could serve as a model for like-minded countries to imitate or join within a multilateral framework, potentially saving millions of lives under one common cause. The United States and China may very well have the most disparate regulatory and political systems in the world that obstruct global cancer collaboration. Yet, if these obstacles can be broken through, 1–2 million lives could be saved annually. Extrapolation of data shows that a coalition of the six regions worldwide with the highest cancer burden outside of the United States (China, Japan, the European Union, Brazil, Canada, and India) approving just one lung cancer therapy may save 600,000 patient life years. Full regulatory harmonization for cancer therapies could reduce the risk of death by 10%–20% a year, saving 1–2 million lives.123
Conclusion
To date, China’s role in global cancer clinical trials has been suboptimal because of its policy choices, self-isolation, complex regulatory factors, and increasingly tense political climates in both the United States and China. If fully integrated into international clinical trial networks — or, at the very least, into bilateral U.S.-China scientific initiatives — invaluable cancer research could be scaled, fast-tracked, and implemented to the benefit of cancer sufferers in both countries and worldwide.
Understanding the challenges to U.S.-China cooperation on cancer research provides a platform for future policy dialogue and stronger scientific ties. Progress on joint cancer trials can help overcome structural challenges within U.S.-China geopolitics while delivering on a global public good for humanity. As experts have remarked, health cooperation between the two countries cannot be left on the backburner.124 President Donald Trump has indicated interest in solving global problems with China early in his administration, and joint clinical trials and regulatory harmonization may provide actionable pathways to address the growing cancer burdens in both countries while ameliorating a foundational global health challenge.
Coordinating a bilateral framework for cancer clinical trials and taking steps toward harmonizing regulatory measures is in the national interests of both countries. If successful, closer U.S.-China collaboration on cancer research can bring China into larger, multilateral oncology research efforts, harness and develop American life sciences innovation, and, most of all, benefit the world’s most consequential state-to-state relationship.
Endnotes
- Bob T. Li et al., “Advancing Global Health Equity: Enhancing Clinical Trials Access and Cooperation to Save Millions of Lives from Cancer,” Asia Society Policy Institute, Center for China Analysis, November 2023, 14, https://asiasociety.org/policy-institute/advancing-global-health-equity.
- Bob T. Li, “Advancing Global Health Equity in Oncology Clinical Trial Access,” Cancer Discovery 14, no. 12 (2024): 2317–23.
- Bobby Daly et al., “We Need a Global System for Testing and Approving Cancer Treatments,” Harvard Business Review, October 18, 2022, https://hbr.org/2022/10/we-need-a-global-system-for-testing-and-approvi….
- “Secretary Blinken’s Visit to the People’s Republic of China (PRC),” U.S. Department of State, Press Release, June 19, 2023, https://2021-2025.state.gov/secretary-blinkens-visit-to-the-peoples-rep….
- “Readout of President Joe Biden's Meeting with President Xi Jinping of the People’s Republic of China,” U.S. Embassy and Consulates in China, Press Release, November 17, 2023, https://china.usembassy-china.org.cn/readout-of-president-joe-bidens-me…; and Sophia Hirshfield and J. Stephen Morrison, “The Health Security Outcomes of APEC and the Biden-Xi Dialogue,” Center for Strategic and International Studies, December 19, 2023, https://www.csis.org/analysis/health-security-outcomes-apec-and-biden-x…
- Xie Feng, “Act with a Sense of Responsibility for History, the People and the World and Usher In a Brighter Future for China-U.S. Relations — Remarks by H.E. Ambassador Xie Feng at the Reception Celebrating the 45th Anniversary of the Establishment of Diplomatic Relations Between China and the United States and the 2024 Chinese New Year,” Ambassador of the People’s Republic of China (PRC) to the United States of America, January 17, 2024, http://us.china-embassy.gov.cn/eng/dshd/202401/t20240118_11228228.htm.
- “President Xi Jinping Meets with U.S. President Joe Biden in Lima,” Ministry of Foreign Affairs (PRC), Press Release, November 17, 2024, https://www.fmprc.gov.cn/eng/zy/jj/xjpcxapecg20/202411/t20241117_115276….
- Wu Dawei, “Cancer Clinical Trial Sites Moving Globalization and Professional Development Forward,” Drug Information Association, August 2021, https://globalforum.diaglobal.org/issue/august-2021/cancer-clinical-tri….
- Sandra Barbosu, “How Innovative Is China in Biotechnology?” Information Technology and Innovation Foundation, July 30, 2024, https://itif.org/publications/2024/07/30/how-innovative-is-china-in-bio….
- George Baeder and Eric Zhang, “How China Is Changing the Clinical Development Landscape: Implications for Global Development Strategy,” Drug Information Association, October 2019, https://globalforum.diaglobal.org/issue/october-2019/how-china-is-chang….
- “中共中央 国务院印发 《’健康中国2030’规划纲要》” [The State Council and Central Committee Issue the “Healthy China 2030” Planning Outline], State Council (PRC), October 25, 2016, http://www.gov.cn/zhengce/2016-10/25/content_5124174.htm; and “China Overall 5-Year Cancer Survival Rate to Reach 46.6% by 2030,” Global Times, November 15, 2023, https://www.globaltimes.cn/page/202311/1301910.shtml.
- Tina Hou et al., “Managing China’s Growing Oncology Burden,” McKinsey & Company, August 26, 2020, https://www.mckinsey.com/industries/life-sciences/our-insights/managing….
- “2023–2028年中国肿瘤医院行业发展监测及市场发展潜力预测报告” [2023–2028 China Oncology Hospital Industry Development Monitoring and Potential Market Development Forecast Report], Huajing Industrial Research Institute, https://www.huaon.com/channel/medicine/868059.html.
- Helen Chen et al., “Opportunities and Patient Insights into the China Oncology Market,” L.E.K. Consulting, Asia-Pacific Life Sciences Centre of Excellence, January 10, 2020, https://www.lek.com/insights/ei/opportunities-and-patient-insights-chin….
- Reynald Castañeda and Andrew Hillman, “The Great Wall: Why Overseas Sponsors Are Yet to Fully Tap into China’s Clinical Trial Resources,” Clinical Trials Arena, May 13, 2022, https://www.clinicaltrialsarena.com/features/china-clinical-trial-chall….
- Annalee Armstrong, “Big Pharma Rushes to China for Deal Prospecting Despite Regulatory Uncertainty,” BioSpace, January 7, 2025, https://www.biospace.com/business/big-pharma-rushes-to-china-for-deal-p….
- “NMPA Holds Symposium on Process and Prospects of ICH in China,” National Medical Products Administration (PRC), Press Release, April 10, 2021, https://english.nmpa.gov.cn/2021-04/10/c_610224.htm.
- Giorgio Sirugo, Sarah A. Tishkoff, and Scott M. Williams, “The Missing Diversity in Human Genetic Studies,” Cell 177, no. 1 (2019): 26–31.
- Zhouliang Bian et al., “The Scale, Collections, and Biospecimen Distribution of Grade A Tertiary Hospital Biobanks in China: A National Survey,” Frontiers in Medicine 7 (2020).
- Wen Ju et al., “Cancer Statistics in Chinese Older People, 2022: Current Burden, Time Trends, and Comparisons with the U.S., Japan, and the Republic of Korea,” Science China Life Sciences 66, no. 5 (2023): 1079–91.
- Farah Master, “China’s Population Drops for Second Year, with Record Low Birth Rate,” Reuters, January 17, 2024, https://www.reuters.com/world/china/chinas-population-drops-2nd-year-ra….
- “Succeeding in International Clinical Trials,” MESM, https://www.mesm.com/resources/succeeding-in-international-clinical-tri….
- Beth Uznis Johnson, “Genetic Data Impacts Clinical Cancer Care,” University of Michigan, Rogel Cancer Center, 2020, https://www.rogelcancercenter.org/illuminate/genetic-data-impacts-clini….
- Wen-ching Sung, “Within Borders: Risks and the Development of Biobanking in China,” in Human Genetic Biobanks in Asia: Politics of Trust and Scientific Advancement, ed. Margaret Sleeboom-Faulkner (London: Routledge, 2008), 169; and Yongxi Chen and Lingqiao Song, “China: Concurring Regulation of Cross-Border Genomic Data Sharing for Statist Control and Individual Protection,” Human Genetics 137, no. 8 (2018): 606.
- “人类遗传资源管理条例(送审稿)公开征求意见” [Regulations on the Administration of Human Genetic Resources (Draft for Review)], Ministry of Science and Technology (PRC), October 31, 2012, art. 38 and 40, https://www.gov.cn/gzdt/att/att/site1/20121031/001e37419a4211fab9e902.d….
- Ibid., art. 16, 19, and 32.
- “人类遗传资源管理条例” [Regulations on the Administration of Human Genetic Resources], Ministry of Science and Technology (PRC), March 28, 2019, art. 41, https://www.gov.cn/zhengce/content/2019-06/10/content_5398829.htm; “科学技术部关于公开征求《人类遗传资源管理条例实施细则(征求意见稿)》意见的通知” [Notice of the Ministry of Science and Technology on the Public Solicitation of the “Implementation Rules for the Human Genetic Resources Regulation (Draft for Comment)”], Ministry of Science and Technology (PRC), March 22, 2022, art. 49, https://www.most.gov.cn/tztg/202203/t20220322_179904.html; and John Balzano, Aaron Gu, and Weishi Li, “Key Takeaways from China’s Regulation on the Administration of Human Genetic Resources,” Covington & Burling LLP, June 18, 2019, https://www.cov.com/-/media/files/corporate/publications/2019/06/key_ta….
- “科学技术部关于公开征求《人类遗传资源管理条例实施细则(征求意见稿)》意见的通知”; and Xiaotian Cui, Wei Han, and Moting Jiang, “Cover Story: China Set to Ease Controls on Genetic Resources to Plug Biotech Innovation Gap,” Caixin, May 20, 2024, https://www.caixinglobal.com/2024-05-20/cover-story-china-set-to-ease-c….
- “人类遗传资源管理条例实施细则” [Implementation Rules of the Regulations on the Management of Human Genetic Resources], Ministry of Science and Technology (PRC), May 26, 2023, art. 2 and 27, https://www.most.gov.cn/xxgk/xinxifenlei/zc/gz/202306/P0202306014217146…; and Todd Liao et al., “How China’s Detailed Genetic Resources Rules May Impact Multinational Life Science Companies,” Morgan Lewis, June 5, 2023, https://www.morganlewis.com/pubs/2023/06/how-chinas-detailed-human-gene….
- Cui, Han, and Jiang, “Cover Story: China Set to Ease Controls on Genetic Resources to Plug Biotech Innovation Gap.”
- Yu Yao and Fei Yang, “Overcoming Personal Information Protection Challenges Involving Real-World Data to Support Public Health Efforts in China,” Frontiers in Public Health 11 (2023).
- “中华人民共和国个人信息保护法” [Personal Information Protection Law of the People’s Republic of China], State Council (PRC), August 20, 2021, art. 38 and 40, https://www.gov.cn/xinwen/2021-08/20/content_5632486.htm.
- “数据出境安全评估办法” [Measures for the Security Assessment of Data Exports], Cyberspace Administration of China, July 7, 2022, art. 4 and 19, https://www.cac.gov.cn/2022-07/07/c_1658811536396503.htm.
- Sun Yu, “China’s Sluggish Approval of Data Exports Leaves Companies Struggling,” Financial Times, January 2, 2024, https://www.ft.com/content/d38b46be-7184-468f-b0ea-1f143fcf1164.
- Dyani Lewis, “China’s Souped-Up Data Privacy Laws Deter Researchers,” Nature, May 25, 2023, https://www.nature.com/articles/d41586-023-01638-1.
- “关于《规范和促进数据跨境流动规定(征求意见稿)》公开征求意见的通知” [Notice of the State Internet Information Office on the Public Solicitation of Opinions on the “Regulations on Regulating and Promoting Cross-Border Data Flow (Draft for Solicitation of Comments)”], Cyberspace Administration of China, September 28, 2023, available at https://www.moj.gov.cn/pub/sfbgw/lfyjzj/lflfyjzj/202309/t20230928_48715….
- Martin Chorzempa and Samm Sacks, “China’s New Rules on Data Flows Could Signal a Shift Away from Security Toward Growth,” Peterson Institute for International Economics, October 3, 2023, https://www.piie.com/blogs/realtime-economics/chinas-new-rules-data-flo….
- “促进和规范数据跨境流动规定” [The Regulations on Cross-Border Data Flows], Cyberspace Administration of China, March 22, 2024, art. 5, 7, and 8, https://www.cac.gov.cn/2024-03/22/c_1712776611775634.htm.
- “国家互联网信息办公室关于《个人信息出境个人信息保护认证办法(征求意见稿)》公开征求意见的通知” [Notice of the State Internet Information Office on the Public Solicitation of Opinions on the “Measures for the Protection and Certification of Personal Information Out of the Country” (Draft for Solicitation of Comments)], Cyberspace Administration of China, January 3, 2025, https://www.cac.gov.cn/2025-01/03/c_1737600915141373.htm; and Shunsuke Tabeta, “China Releases Draft Rules on Cross-Border Personal Data Transfer,” Nikkei Asia, January 7, 2025, https://asia.nikkei.com/Business/Technology/China-releases-draft-rules-….
- “中华人民共和国国家安全法” [National Security Law of the People’s Republic of China], State Council (PRC), July 1, 2015, art. 29, http://www.gov.cn/zhengce/2015-07/01/content_2893902.htm; and Cong Cao, “China’s Evolving Biosafety/Biosecurity Legislations,” Journal of Law and the Biosciences (2021): 19.
- “国务院办公厅印发《关于促进和规范健康医疗大数据应用发展的指导意见》” [The General Office of the State Council issued the “Guiding Opinions on Promoting and Regulating the Development of Health and Medical Big Data Applications”], General Office of the State Council (PRC), June 24, 2021, https://www.gov.cn/xinwen/2016-06/24/content_5085211.htm.
- “中华人民共和国生物安全法” [Biosecurity Law of the People’s Republic of China], State Council (PRC), October 18, 2020, art. 53 and 56, https://www.gov.cn/xinwen/2020-10/18/content_5552108.htm.
- Timothy R. Heath, “The ‘Holistic Security Concept’: The Securitization of Policy and Increasing Risk of Militarized Crisis,” RAND Corporation, June 27, 2015, https://www.rand.org/blog/2015/06/the-holistic-security-concept-the-sec…; and “总体国家安全观 | 一文读懂总体国家安全观” [Holistic National Security | One Article to Understand Holistic National Security], Guangxi Zhuang Autonomous Province Department of Ecology and Environment, April 13, 2022, http://sthjt.gxzf.gov.cn/ttxw/t11755099.shtml.
- Jessie Yeung, “China’s Sitting on a Goldmine of Genetic Data – and It Doesn’t Want to Share,” CNN, August 12, 2023, https://www.cnn.com/2023/08/11/china/china-human-genetic-resources-regu….
- “国务院关于印发《中国制造2025》的通知” [Notice of the State Council on the Issuance of “Made in China 2025”], State Council (PRC), May 8, 2015, https://www.gov.cn/zhengce/content/2015-05/19/content_9784.htm.
- Barbosu, “How Innovative Is China in Biotechnology?”
- Li Qiang, “Report on the Work of the Government: Delivered at the Second Session of the 14th National People’s Congress of the People’s Republic of China on March 5, 2024,” Premier of the State Council, 16–17, available at https://npcobserver.com/wp-content/uploads/2024/03/2024-Government-Work….
- “关于人类遗传资源管理工作由科学技术部负责调整为国家卫生健康委员会负责的公告” [Announcement on the Adjustment of the Management of Human Genetic Resources from the Ministry of Science and Technology to the National Health Commission], Ministry of Science and Technology (PRC), April 25, 2024, https://www.most.gov.cn/tztg/202404/t20240425_190494.html; and “中华人民共和国国务院令第777号” [Order of the State Council of the People’s Republic of China No. 777], State Council (PRC), March 10, 2024, https://www.gov.cn/zhengce/content/202403/content_6939590.htm.
- Cui, Han, and Jiang, “Cover Story: China Set to Ease Controls on Genetic Resources to Plug Biotech Innovation Gap.”
- “全国首个获批数据出境安全评估案例落地北京” [The Country’s First Approved Data Exit Security Assessment Case Landed in Beijing], Beijing Municipal Internet Information Office, January 18, 2023, available at https://mp.weixin.qq.com/s/mCS7dZIuqs7LCevDUnd58g.
- “关于印发健康中国行动—癌症防治行动实施方案(2023—2030年)的通知” [Notice on the Issuance of the Implementation Plan of the Healthy China Action—Cancer Prevention and Control Action (2023–2030)], National Health Commission (PRC), November 14, 2023, art. 21, http://www.nhc.gov.cn/ylyjs/pqt/202311/18bd5bb5abc74ebc896f9d5c9ca63422….
- “商务部 国家卫生健康委 国家药监局关于在医疗领域开展扩大开放试点工作的通知” [Notice of the National Health Commission, the Ministry of Commerce, and the National Medical Products Administration on the Pilot Work of Expanding Opening Up in the Medical Sector], State Council (PRC), September 7, 2024, https://www.gov.cn/zhengce/zhengceku/202409/content_6973072.htm; and He Huifeng and Mandy Zuo, “China Opens Up Medical Sector, Manufacturing to Foreign Ownership in Growth Push,” South China Morning Post, September 8, 2024, https://www.scmp.com/economy/china-economy/article/3277683/china-opens-….
- “国务院关于进一步优化外商投资环境加大吸引外商投资力度的意见” [Opinions of the State Council on Further Optimizing the Foreign Investment Environment and Increasing Efforts to Attract Foreign Investment], State Council (PRC), August 13, 2023, https://www.gov.cn/zhengce/content/202308/content_6898048.htm.
- “中共中央关于进一步全面深化改革推进中国式现代化的决定” [The Decision of the Central Committee of the Communist Party of China on Further Comprehensively Deepening Reform and Promoting Chinese-Style Modernization], Xinhua, July 21, 2024, art. 6, http://www.news.cn/politics/20240721/cec09ea2bde840dfb99331c48ab5523a/c….
- “国务院办公厅关于印发《扎实推进高水平对外开放更大力度吸引和利用外资行动方案》的通知” [Notice of the General Office of the State Council on the Issuance of the “Action Plan for Firmly Promoting High-level Opening Up to the Outside World and Making Greater Efforts to Attract and Use Foreign Investment”], State Council (PRC), March 19, 2024, https://www.gov.cn/zhengce/zhengceku/202403/content_6940155.htm; and Evelyn Cheng, “China Calls on Foreign Businesses to Share Their Problems as Investment Slumps,” CNBC, February 29, 2024, https://www.cnbc.com/2024/03/01/china-calls-on-foreign-businesses-to-sh….
- “MOFCOM Holds Round-Table with Global Pharmaceutical Companies,” Pharmaceutical Research and Manufacturers of America, March 28, 2024, available at https://mp.weixin.qq.com/s/EE3VM1MykW4Y5kp5SFjUyg.
- “2024年“中美癌症防治论坛”在津成功举办” [The 2024 “Sino-U.S. Cancer Prevention and Treatment Forum” Was Successfully Held in Tianjin] Peking University, Institute for Global Health and Development, June 20, 2024, available at https://mp.weixin.qq.com/s/vfpVZCQYtosSasCHPdIG1w.
- “Readout of Second Meeting of U.S.-China Commercial Issues Working Group,” U.S. Department of Commerce, International Trade Administration, Press Release, September 9, 2024, https://www.trade.gov/press-release/readout-second-meeting-us-china-com….
- “China, U.S. Health Departments Agree to Strengthen Institutional Dialogue,” State Council (PRC), October 1, 2024, https://english.www.gov.cn/news/202410/01/content_WS66fb7a4ec6d0868f4e8….
- “Information About the Department of Justice’s China Initiative and a Compilation of China-Related Prosecutions Since 2018,” U.S. Department of Justice, November 19, 2021, https://www.justice.gov/archives/nsd/information-about-department-justi….
- Robert Daly, “The Post-Reform Period: Educational Exchange and Sino-U.S. Rivalry,” in Finding Firmer Ground: The Role of Higher Education in U.S.-China Relationship, ed. Yawei Liu and Michael Cerny (Atlanta: Carter Center, 2022), 55; and “Advocacy Groups, Community Organizations and Science Associations Urge President-Elect Joe Biden to End Justice Department’s ‘China Initiative,’” Asian Americans Advancing Justice, Press Release, January 5, 2021, https://www.advancingjustice-aajc.org/press-release/advocacy-groups-com….
- Ryan Lucas, “The Justice Department Is Ending Its Controversial China Initiative,” NPR, February 23, 2022, https://www.npr.org/2022/02/23/1082593735/justice-department-china-init….
- Ruixue Jia et al., “The Impact of U.S.-China Tensions on U.S. Science,” National Bureau of Economic Research, working paper, no. 29941, 23–25, https://www.nber.org/system/files/working_papers/w29941/w29941.pdf.
- Yu Xie et al., “Caught in the Crossfire: Fears of Chinese-American Scientists,” Proceedings of the National Academy of Sciences of the United States of America 120, no. 27 (2023).
- Bochen Han, “Bill Reviving U.S. Justice Department’s ‘China Initiative’ Passes House of Representatives,” South China Morning Post, September 12, 2024, https://www.scmp.com/news/china/article/3278161/bill-reviving-us-justic….
- Claire Dietz, “Emory Fires Two NIH-Funded Faculty Members for Not Disclosing Foreign Sources of Funding and Work in China,” Cancer Letter 45, no. 24 (2019); and Todd Ackerman, “MD Anderson Ousts 3 Scientists over Concerns About Chinese Conflicts of Interest,” Houston Chronicle, April 20, 2019, https://www.houstonchronicle.com/news/houston-texas/houston/article/MD-….
- Jia et al., “The Impact of U.S.-China Tensions on U.S. Science.”
- Dannie Peng, “China Initiative Inquiries Left Researchers Feeling ‘Targeted, Alienated,’ U.S. Agency Says,” South China Morning Post, August 26, 2024, https://www.scmp.com/news/china/science/article/3275910/china-initiativ….
- Ling Xin, “World-Leading Chinese Cancer Scientist Sun Shao-Cong Has Left U.S. for Beijing,” South China Morning Post, December 17, 2024, https://www.scmp.com/news/china/science/article/3291009/world-leading-c…; Jeffrey Mervis, “Pall of Suspicion,” Science, March 23, 2023, https://www.science.org/content/article/pall-suspicion-nihs-secretive-c…; and Victoria Bela and Dannie Peng, “Nanotech Pioneer Wang Zhonglin Leaves U.S. to Work in China ‘Full Time,’” South China Morning Post, September 24, 2024, https://www.scmp.com/news/china/science/article/3279730/nanotechnology-….
- “McCaul on Executive Order Curbing U.S. Tech Investment in China,” U.S. House Foreign Affairs Committee, Press Release, August 9, 2023, https://foreignaffairs.house.gov/press-release/mccaul-on-executive-orde…; “Genomics Data Security Act,” 117th U.S. Congress, S. 1744, May 20, 2021, https://www.govinfo.gov/content/pkg/BILLS-117s1744is/pdf/BILLS-117s1744…; “GENE Act,” 117th U.S. Congress, S. 1745, May 20, 2021, https://www.congress.gov/117/bills/s1745/BILLS-117s1745is.pdf; “GENE Act,” 118th U.S. Congress, S. 1827, June 6, 2023, https://www.congress.gov/118/bills/s1827/BILLS-118s1827is.pdf; and “Rubio Introduces Bills to Counter Growing Threat of China’s Collection of American’s [sic] Genomic Data,” Office of Senator Marco Rubio, Press Release, May 20, 2021, https://web.archive.org/web/20231203043058/https://www.rubio.senate.gov….
- U.S. Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party (Select Committee on the CCP), Reset, Prevent, Build: A Strategy to Win America’s Economic Competition with the Chinese Communist Party (Washington, D.C., December 2023), https://selectcommitteeontheccp.house.gov/sites/evo-subsites/selectcomm….
- “Moolenaar, Lawmakers Uncover Evidence of U.S. Pharmaceutical Companies Working with Chinese Military and in Xinjiang, Asks FDA to Investigate,” Select Committee on the CCP, Press Release, August 20, 2024, https://selectcommitteeontheccp.house.gov/media/press-releases/moolenaa…; and Maya Goldman, “Congress Probes Pharma Work with Chinese Military,” Axios, August 21, 2024, https://www.axios.com/2024/08/21/congress-investigate-pharma-clinical-t….
- “Moolenaar, Krishnamoorthi, Dunn Recommend Strengthened Controles [sic] to Prohibit the PLA from Accessing U.S. Clinical Trial Data,” Select Committee on the CCP, Press Release, January 10, 2025, https://selectcommitteeontheccp.house.gov/media/press-releases/moolenaa….
- “Bill to Ban Foreign Adversary Biotech Companies, Including BGI Group,” Select Committee on the CCP, January 25, 2024, https://selectcommitteeontheccp.house.gov/media/bills/bill-ban-foreign-….
- Oliver Barnes, Ian Johnston, and Eleanor Olcott, “Drugmakers Race to Find Alternative Suppliers as U.S. Cracks Down on Chinese Biotech,” Financial Times, April 11, 2024, https://www.ft.com/content/bfe48705-5610-4b6d-bbe4-0844f50483b2; and Jared S. Hopkins and Clarence Leong, “U.S. Drugmakers Are Breaking Up With Their Chinese Supply-Chain Partners,” Wall Street Journal, November 1, 2024, https://www.wsj.com/health/pharma/china-manufacturing-astrazeneca-suppl….
- Jake Sullivan, “Remarks by National Security Advisor Jake Sullivan at the Special Competitive Studies Project Global Emerging Technologies Summit,” White House, September 16, 2022.
- “Additions and Revisions of Entities to the Entity List,” Federal Register, March 6, 2023, https://www.federalregister.gov/documents/2023/03/06/2023-04558/additio….
- “Justice Department Issues Comprehensive Proposed Rule Addressing National Security Risks Posed to U.S. Sensitive Data,” U.S. Department of Justice, Press Release, October 21, 2024, https://www.justice.gov/opa/pr/justice-department-issues-comprehensive-proposed-rule-addressing-national-security-risks; Riley Griffin and Mackenzie Hawkins, “U.S. Seeks to Limit China’s Access to Americans’ Personal Data,” Bloomberg, February 28, 2024, https://www.bloomberg.com/news/articles/2024-02-28/us-data-security-ord…; and “Justice Department Issues Final Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data,” U.S. Department of Justice, Press Release, December 27, 2024, https://www.justice.gov/opa/pr/justice-department-issues-final-rule-add….
- “Commerce Implements New Controls to Address National Security Risks Related to Biotechnology,” U.S. Department of Commerce, Press Release, January 15, 2025, https://www.bis.gov/press-release/commerce-implements-new-controls-addr….
- U.S. Department of Defense, Military and Security Developments Involving the People’s Republic of China 2023 (Washington, D.C., October 2023), 114–15, https://media.defense.gov/2023/Oct/19/2003323409/-1/-1/1/2023-MILITARY-…; and Cate Brown and Joby Warrick, “China’s Quest for Human Genetic Data Spurs Fears of a DNA Arms Race,” Washington Post, September 21, 2023, https://www.washingtonpost.com/world/interactive/2023/china-dna-sequenc….
- Kirsty Needham and Clare Baldwin, “China’s Gene Giant Harvests Data from Millions of Women,” Reuters, July 7, 2021, https://www.reuters.com/investigates/special-report/health-china-bgi-dna.
- Michael Martina, Michael Erman, and Karen Freifeld, “Exclusive: China’s WuXi AppTec Shared U.S. Client’s Data with Beijing, U.S. Intelligence Officials Told Senators,” Reuters, March 28, 2024, https://www.reuters.com/technology/chinas-wuxi-apptec-shared-us-clients….
- “2024 Report to Congress of the U.S.-China Economic and Security Review Commission,” U.S.-China Economic and Security Review Commission, November 2024, 215–20, https://www.uscc.gov/sites/default/files/2024-11/2024_Annual_Report_to_…; and U.S. Department of State, Report on Biotechnology in the People’s Republic of China’s Military-Civil Fusion Strategy (Washington, D.C., October 2024), 12–13, https://www.state.gov/wp-content/uploads/2024/11/ISAB-Report-on-Biotech….
- “The Chinese Communist Party’s Coronavirus Cover-Up,” U.S. House Foreign Affairs Committee (GOP), June 22, 2020, https://foreignaffairs.house.gov/chinas-coronavirus-cover-up; and Michael R. Gordon and Dustin Volz, “CIA Now Favors Lab Leak Theory on Origins of COVID-19,” Wall Street Journal, January 25, 2025, https://www.wsj.com/politics/national-security/cia-now-favors-lab-leak-….
- “Expiration of U.S.-China Science and Technology Cooperation Agreement Will Have Consequences for Scientific Exchange, Progress, Science Group Says,” Union of Concerned Scientists, February 27, 2024, https://www.ucsusa.org/about/news/us-china-science-cooperation-needed-p…; “Continuing U.S.-China Scientific Collaboration in an Era of Heightened Concern,” Hoover Institution, December 3, 2024, https://www.hoover.org/news/continuing-us-china-scientific-collaboratio…; and “U.S.-China Cooperative Agenda: A Progressive, Principled, and Pragmatic Policy Framework on China, Chapter 8,” Center for American Progress, April 11, 2024, https://www.americanprogress.org/article/a-progressive-principled-and-p….
- Li et al., “Advancing Global Health Equity: Enhancing Clinical Trials Access and Cooperation to Save Millions of Lives from Cancer,” 16.
- Yew Lun Tian, “China Fines Mintz $1.5 Mln for ‘Unapproved’ Work, After Raiding Its Beijing Office,” Reuters, August 22, 2023, https://www.reuters.com/world/china/china-fines-mintz-15-mln-unapproved…; and Daisuke Wakabayashi and Keith Bradsher, “U.S. Consulting Firm Is the Latest Target of a Chinese Crackdown,” New York Times, April 27, 2023, https://www.nytimes.com/2023/04/27/business/bain-china.html.
- Vanessa Cai, “China’s Spy Agency Warns Foreign Groups Are Using Consulting ‘As a Cover’ to Steal Secrets,” South China Morning Post, March 28, 2024, https://www.scmp.com/news/china/politics/article/3257092/chinas-spy-age….
- Arjun Neil Alim, Oliver Barnes, and Ian Johnston, “Pharma Groups Warn of Supply Crunch over China Spying Law,” Financial Times, April 21, 2024, https://www.ft.com/content/1d52d75f-5b54-4c27-bdd4-65409f64c64a.
- Kiyoshi Takenaka and Kaori Kaneko, “China Formally Arrests Astellas Employee Suspected of Spying, Japan Urges Release,” Reuters, October 19, 2023, https://www.reuters.com/world/china/china-formally-arrests-astellas-emp…; and “Japan’s Astellas Says Employee Indicted by China’s Prosecutors,” Reuters, August 21, 2024, https://www.reuters.com/business/healthcare-pharmaceuticals/japans-aste….
- Yoko Kubota and Raffaele Huang, “China Detains AstraZeneca Employees over Alleged Transport of Unapproved Drug,” Wall Street Journal, September 5, 2024, https://www.wsj.com/world/china/china-detains-astrazeneca-employees-ove…; and Yoko Kubota and Joseph Walker, “AstraZeneca Probe in China Adds to Concerns for Foreign Businesses,” Wall Street Journal, October 31, 2024, https://www.wsj.com/world/china/astrazeneca-probe-in-china-adds-to-concerns-for-foreign-businesses-eff0c93f.
- “Imposing Duties to Address the Synthetic Opioid Supply Chain in the People’s Republic of China,” White House, Press Release, February 1, 2025, https://www.whitehouse.gov/presidential-actions/2025/02/imposing-duties…; “不可靠实体清单工作机制关于将美国PVH集团和因美纳公司列入不可靠实体清单的公告” [Announcement of the Working Mechanism of the List of Unreliable Entities on the Inclusion of the United States’ PVH Group and Illumina in the List of Unreliable Entities], Ministry of Commerce (PRC), February 4, 2025, https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_ab15d2258dda4e93b8ad1e…; and Meridith McGraw, “Trump: Chinese Tariffs Are ‘Opening Salvo,’” Wall Street Journal, February 3, 2025, https://www.wsj.com/livecoverage/stock-market-today-dow-sp500-nasdaq-live-020-03-2025/card/trump-chinese-tariffs-are-opening-salvo--Daj32rEgkwSCAbivpGnZ.
- Jennifer Johnson, “Why ‘Big Pharma’ Will Be the Next China Trade War Battleground,” Investor’s Chronicle, September 20, 2024, https://www.investorschronicle.co.uk/content/dfb1b7a4-342d-5904-b30b-43…; and Fraiser Kansteiner, “Trump Tariffs Threaten U.S. Drug Supplies and Risk Higher Prices, Trade Groups Warn,” Fierce Pharma, February 3, 2025, https://www.fiercepharma.com/pharma/trump-tariffs-could-stymie-us-gener….
- Xinlu Liang, “40,000 Punished in China’s Medical Corruption Crackdown, Including over 350 Top Figures,” South China Morning Post, January 1, 2025, https://www.scmp.com/news/china/politics/article/3293019/40000-punished…; Xu Wen et al., “Cover Story: Anti-Corruption Storm Sweeps China’s Health-Care Industry,” Caixin, August 14, 2023, https://www.caixinglobal.com/2023-08-14/cover-story-anti-corruption-sto…; “从国家监委报告看惩治‘微腐败’新成效” [Judging from the Report of the National Supervision Commission, the New Effectiveness of Punishing “Micro-Corruption”], National Healthcare Security Administration (PRC), December 25, 2024, https://www.nhsa.gov.cn/art/2024/12/25/art_52_15245.html; and Lan Zong, “国家监委:严查靠医吃医、套取医保资金等腐败问题,全国处分4万人” [National Supervision Commission: Strictly Investigate Corruption Issues Such as Relying on Medical Treatment and Obtaining Medical Insurance Funds, and Punish 40,000 People Nationwide], Shanghai Observer, December 26, 2024, https://www.jfdaily.com/wx/detail.do?id=834153.
- “中国共产党第二十届中央纪律检查委员会第三次全体会议公报” [Communiqué of the Third Plenary Meeting of the 20th Central Commission for Discipline Inspection of the Communist Party of China], Xinhua, January 10, 2024, https://www.gov.cn/yaowen/liebiao/202401/content_6925201.htm; and “中国共产党第二十届中央纪律检查委员会第四次全体会议公报” [Communiqué of the Fourth Plenary Meeting of the 20th Central Commission for Discipline Inspection of the Communist Party of China], Xinhua, January 8, 2025, http://www.news.cn/politics/leaders/20250108/a5489461a0fc4187a55fab6ca1….
- “关于印发2024年纠正医药购销领域和医疗服务中不正之风工作要点的通知” [Notice on the Issuance of Key Points for Correcting Unfair Practices in the Field of Pharmaceutical Purchase and Marketing and Medical Services in 2024], National Health Commission (PRC), May 17, 2024, https://www.gov.cn/zhengce/zhengceku/202405/content_6953851.htm.
- Yanzhong Huang, “Anti-Corruption Campaign in China’s Medical Sector: Unmasking the Hidden Agenda,” Council on Foreign Relations, August 18, 2023, https://www.cfr.org/blog/anti-corruption-campaign-chinas-medical-sector….
- Jun Ling, “专家呼吁反腐不应‘一刀切’:近期医生不敢参会学习,不敢开进口药,” [Experts Call for Anti-Corruption Should Not Be “One Size Fits All”: Recently, Doctors Dare Not Participate in Meetings and Study, and Dare Not Prescribe Imported Medicines], Medical World, August 12, 2023, available at https://new.qq.com/rain/a/20230811A09O8Y00.
- Alexandra Stevenson and Zixu Wang, “In China, Rare Dissent Over a Program to Save on Drug Costs,” New York Times, January 25, 2025, https://www.nytimes.com/2025/01/25/business/china-pharma-drugs.html.
- Qian Zhou, “2025 Import-Export Tariffs in China: Latest Adjustments,” China Briefing, January 2, 2025, https://www.china-briefing.com/news/china-import-export-tariffs-in-2025.
- Karen M. Sutter and Emily G. Blevins, “U.S.-China Science and Technology Cooperation Agreement,” Congressional Research Service, CRS Report for Congress, IF12510, December 13, 2024, https://crsreports.congress.gov/product/pdf/IF/IF12510; and Deborah Seligsohn, “The Case for Renewing the U.S.-China S&T Cooperation Agreement,” Center for Strategic and International Studies, August 4, 2023, https://www.csis.org/analysis/case-renewing-us-china-st-cooperation-agr….
- Alexander B. Gray, “We Must End the Experiment of Science Cooperation with China,” Hill, September 11, 2023, https://thehill.com/opinion/technology/4194083-its-time-to-end-the-expe…; and “Risch, Colleagues Demand U.S.-China Science and Technology Cooperation Agreement Be Revoked,” U.S. Senate Foreign Relations Committee, Press Release, December 19, 2024, https://www.foreign.senate.gov/press/rep/release/risch-colleagues-deman….
- “Amendment and Extension of the U.S.-PRC Science and Technology Agreement (STA),” U.S. Department of State, Press Release, December 13, 2024, https://2021-2025.state.gov/amendment-and-extension-of-the-u-s-prc-scie….
- Brendan Kelly and Jing Qian, “U.S. and China Just Set New Road Rules for Science Collaboration. Americans Will Benefit If We Don’t Scrap Joint Research,” ChinaFile, January 16, 2025, https://www.chinafile.com/reporting-opinion/viewpoint/us-and-china-just….
- Sutter and Blevins, “U.S.-China Science and Technology Cooperation Agreement”; and Jack Corrigan, James Dunham, and Remco Zwetsloot, “The Long-Term Stay Rates of International STEM PhD Graduates,” Center for Strategic and Emerging Technology, April 2022, https://cset.georgetown.edu/publication/the-long-term-stay-rates-of-int….
- “U.S.-China Program for Biomedical Research Cooperation Preliminary Program Review,” National Cancer Institute, Center for Global Health, https://www.cancer.gov/about-nci/organization/cgh/research-training-pro…; and Richard P. Suttmeier, “Trends in U.S.-China Science and Technology Cooperation: Collaborative Knowledge Production for the Twenty-First Century?” U.S.-China Economic and Security Review Commission, September 11, 2014, https://www.uscc.gov/sites/default/files/Research/Trends%20in%20US-Chin….
- Zhangyu Wang, Benjamin Gregg, and Li Du, “Regulatory Barriers to U.S.-China Collaboration for Generative AI Development in Genomic Research,” Cell Genomics 4, no. 6 (2024).
- Scott Kennedy, “U.S.-China Scholarly Recoupling: Advancing Mutual Understanding in an Era of Intense Rivalry,” Center for Strategic and International Studies, March 27, 2024, https://www.csis.org/analysis/us-china-scholarly-recoupling-advancing-m…; and Jia et al., “The Impact of U.S.-China Tensions on U.S. Science.”
- “Remarks and Q&A by National Security Advisor Jake Sullivan on the Future of U.S.-China Relations,” U.S. Embassy and Consulates in China, February 1, 2024, https://china.usembassy-china.org.cn/remarks-and-qa-by-national-securit….
- “China’s Ambassador to the U.S. Accuses Immigration Officers of Harassing Chinese Students: ‘This Is Absolutely Unacceptable,’” Fortune, January 30, 2024, https://fortune.com/asia/2024/01/30/china-accuses-us-immigration-harass….
- “Amendment and Extension of the U.S.-PRC Science and Technology Agreement (STA).”
- Victoria Bela, “China’s World-Leading Cancer Drug Makes Historic Foray into the U.S. amid Medicine Crisis,” South China Morning Post, November 4, 2023, https://www.scmp.com/news/china/science/article/3240177/chinas-world-le….
- Yuxuan Wei et al., “Cancer Drug Indication Approvals in China and the United States: A Comparison of Approval Times and Clinical Benefit, 2001–2020,” Lancet 45 (2024).
- Daly et al., “We Need a Global System for Testing and Approving Cancer Treatments.”
- Bryanna Entwistle, “Inaugural Cure4Cancer Conference Facilitates Strides Towards Global Health Equity and Harmonization,” Asia Society, December 1, 2023, https://asiasociety.org/new-york/inaugural-cure4cancer-conference-facil….
- Brian Gormley, “U.S. and Other Foreign Venture Firms Pull Back from China’s Biotech Sector,” Wall Street Journal, September 14, 2023, https://www.wsj.com/articles/u-s-and-other-foreign-venture-firms-pull-b….
- John Liu and Dong Lyu, “Astra, Pfizer Boost China Bets Despite U.S. Drive to Decouple,” Bloomberg, March 26, 2024, https://www.bloomberg.com/news/articles/2024-03-26/astra-pfizer-double-…; Andrew Silver and Kane Wu, “Drug Giants Eye China for Deals Despite Growing Sino-U.S. Tensions,” Reuters, July 23, 2024, https://www.reuters.com/business/healthcare-pharmaceuticals/drug-giants…; Rachel Cheung, “Big Pharma Doubles Down on China,” Wire China, November 3, 2024, https://www.thewirechina.com/2024/11/03/big-pharma-doubles-down-on-china; and Peter Loftus, “Behind Moderna’s Quiet Gamble on China,” Wall Street Journal, January 9, 2025, https://www.wsj.com/health/pharma/moderna-is-gambling-on-china-as-other….
- Jennifer Bouey, “U.S.-China Collaboration on HIV/AIDS: Perspectives on Global Health Collaborations amid Geopolitical Changes,” Center for Strategic and International Studies and Brookings Institution, February 2024, 17, https://csis-website-prod.s3.amazonaws.com/s3fs-public/2024-02/230223_B….
- Ibid., 18.
- Ibid., 5.
- Joan Kaufman and Michael Gallo, “U.S.-China Health Relations During COVID-19: Insights from Past Collaborations and Future Considerations,” in COVID-19 and U.S.-China Relations, ed. Zheng Wang (Springer Nature: Switzerland, 2024), 26; and Gayle Smith, “How Foes Can Defeat a Common Enemy: U.S.-China Collaboration to Combat Ebola,” Center for Strategic and International Studies and Brookings Institution, May 2024, 3–4, https://csis-website-prod.s3.amazonaws.com/s3fs-public/2024-05/240521_S….
- Kaufman and Gallo, “U.S.-China Health Relations During COVID-19,” 26.
- Daly et al., “We Need a Global System for Testing and Approving Cancer Treatments.”
- Yanzhong Huang, “Two Geopolitical Rivals, One Health,” Council on Foreign Relations, ThinkGlobalHealth, November 29, 2023, https://www.thinkglobalhealth.org/article/two-geopolitical-rivals-one-h….