On June 1, 2026, the State Council officially announced Order No. 837- "Provisions of the State Council on Outward Investment" (hereinafter referred to as "Order No. 837"), which will come into effect on July 1. As the first administrative regulation in China to regulate foreign investment, it not only sets a clear compliance red line for commercial aerospace going global, but also builds a solid institutional guarantee platform, promoting the industry to bid farewell to the past extensive "going global" and move towards a new stage of standardized, stable, and sustainable internationalization.
1、 The wave of going out to sea: In the past few years, China's commercial aerospace industry has experienced explosive growth, from "sporadic water trials" to "full speed long-distance voyages", and the pace of internationalization continues to accelerate. By 2025, China will have completed 92 space launches, with commercial launches accounting for over 54%. The core industry scale will exceed 2.83 trillion yuan, and it is expected to climb to 3.5 trillion yuan by 2026. At the sea race track, China Science Aerospace Power Arrow 1 took the lead in achieving international launch, with overseas orders exceeding 4 billion yuan, and has provided satellite launch services for Oman, Pakistan and other "the Belt and Road" countries. The overseas model has also expanded from a single satellite export to multiple paths such as launch service output, satellite whole satellite export, joint research and development, and overseas infrastructure construction, and the embryonic form of the "Space Silk Road" has emerged.
But behind the prosperity, challenges follow closely. In terms of cost, the launch cost of commercial rockets in China is about 5000-8000 US dollars per kilogram, while the SpaceX Falcon 9 has dropped to 1500-3000 US dollars per kilogram, and the shortcomings of reusable technology urgently need to be addressed. In the international environment, European and American countries raise the entry threshold through export controls and technical standard barriers, such as the United States restricting the proportion of American technology contained in Chinese satellites to no more than 25%. At the compliance level, the approval cycle for dual-use items in the aerospace industry is long and lacks high-level legal protection. Enterprises often find themselves in a passive position when facing discriminatory measures from overseas. During the National People's Congress and Chinese People's Political Consultative Conference in 2025, Zhang Tao, a member of the National People's Congress, explicitly called for special policy support for commercial aerospace going global.
2、 New regulations implemented: strict management of core technologies, escorting compliant overseas expansion
Order 837 has a total of 34 articles, covering three dimensions of foreign investment services, management, and protection. It has a dual impact of "strict management+escort" on the technology intensive and highly sensitive commercial aerospace industry. （1） Tightening the compliance reins: drawing a clear red line and eliminating gray areas. The core constraint of the new regulations is to strictly control the export of sensitive technologies and data. It is explicitly prohibited to transfer goods, technology, and data that are prohibited from export to foreign countries through cross-border dispatch of technical personnel, overseas training, technical guidance, and other means. This means that key areas such as rocket assembly technology, satellite platform core algorithms, onboard chips, and propellant formulations will be included in the full chain supervision, completely blocking the gray channels that used to evade control through "joint research and development" and "personnel flow".
At the same time, security reviews and penalties for violations have been comprehensively upgraded. Investments involving critical information infrastructure and high-tech sensitive fields (such as aerospace technology) must comply with the approval system and national security review. Without approval, delivery documents cannot be signed or equity changes cannot be completed. The regulatory scope also extends to individual residents. For behaviors such as false filing and concealing information, a maximum fine of 10 ‰ of the investment amount can be imposed, and foreign investment activities are prohibited for 1-3 years, forcing enterprises to establish a sound internal compliance system.
In addition, the approval filing and data supervision are more refined. Before signing international launch contracts and establishing overseas subsidiaries, enterprises must complete the complete approval and filing process. When providing satellite remote sensing data, measurement and control data, etc. to overseas markets, it is also necessary to comply with data security and technology export regulations, clarify data export boundaries, and provide legal basis for enterprises. （2） Strengthening the escort barrier: policy support, resolving concerns after going abroad. While tightening constraints, the new regulations also provide a "policy gift package" for compliant enterprises going abroad, offering comprehensive institutional protection.
Overseas barriers now have countermeasures. The new regulations establish an investigation and countermeasures mechanism for investment barriers and discriminatory measures. If a company encounters unreasonable trade restrictions, unreasonable asset freezes, or political interference that disrupts contracts overseas, it can legally request the national level to initiate investigations and take countermeasures, completely changing the passive situation of "fighting alone" in the past.
The conventional sea going process is simplified. For routine businesses that do not involve sensitive technologies and national security, such as commercial satellite manufacturing, launch services, overseas production capacity cooperation, etc., the filing system still applies. The state supports market-oriented international cooperation, which is beneficial for enterprises with mature commercialization capabilities to expand their markets with light equipment.
Simultaneous increase in service and investment and financing support. The new regulations clarify and improve the comprehensive overseas service system, coordinate resources such as foreign affairs, law, finance and taxation, and finance, and provide public services such as overseas policy interpretation, compliance consulting, and intellectual property protection for enterprises. At the same time, banks are encouraged to provide financing services for foreign investment, and policy insurance institutions provide overseas investment insurance to alleviate the financial pressure of commercial aerospace heavy assets and long-term capital, and reduce overseas risk exposure.
3、 Industry Reshaping: From 'Wild Growth' to 'Fleet Voyage'
Overall, the impact of Order 837 on commercial aerospace going global is characterized by "tightening and loosening, establishing first and then breaking": short-term compliance costs have increased, and the extensive mode of going global is difficult to sustain; In the long run, by clarifying rules and strengthening guarantees, we will promote the industry to move from "dispersed trial waters" to "fleet voyages" and achieve high-quality international development.
From the perspective of enterprises, compliance capability will become the core competitiveness for going global. Enterprises that take the lead in establishing a sound compliance system and understanding policy boundaries can not only avoid risks, but also win customer trust in the international market and seize development opportunities.
From an industrial perspective, Order 837 and the National Space Administration's "Action Plan for Promoting High Quality and Safe Development of Commercial Aerospace (2025-2027)" form a policy synergy to promote the industry to bid farewell to disorderly competition, focus on breakthroughs in core technologies and compliance capacity building, and build an independent, controllable, safe, and efficient industrial ecosystem.
From a national perspective, this is the first time that China has provided a systematic legal framework for foreign investment through administrative regulations. For strategic industries such as commercial aerospace, it is not only a manifestation of the country's confidence in supporting industry internationalization, but also an important institutional layout for safeguarding national overseas interests and ensuring industrial chain security.
As emphasized at the beginning of Order 837, 'Adhere to the basic national policy of opening up to the outside world, coordinate development and security'. For China's commercial aerospace industry, the new regulations are not a "stumbling block" to going out to sea, but a "ballast stone" for long-distance voyages. In the future, the industry will steadily expand its global market under a compliance framework, allowing China's aerospace technology and services to shine in a broader sky.
