Briefing note, built 2026-10-25 from 50,271 Chinese government documents (3,734 central, 46,523 provincial and local, 14 whose issuer is not yet placed) and UN Comtrade. Every number below is on the Insights page with its sample, interval and method.
In brief
Import-substitution language stepped up in China's industrial policy in 2020–22 and has stayed there; that language comes with money attached, and the trade data are consistent with it working in some of the product lines Europe and Switzerland sell. Central directives still reach most provinces within months, but provinces restate fewer of the directives issued since 2022, and a pre-registered test cannot yet rule out no change; either way the provincial layer, where the money is, has to be watched directly.
Five findings
1. Substitution language stepped up around 2020, and it carries money. Sector policy documents calling for 国产替代, 进口替代, 自主可控 or 卡脖子 fixes went from 1.9% in 2017–19 (95% CI 1.0%–3.5%) to 6.4% in 2020–22 (4.8%–8.4%), and were 6.1% in 2023–26; a steady yearly rise is not established (odds ×1.03 a year, 95% CI 0.99–1.07; 3,834 documents). 49% of the documents that use it carry operative support measures, against 30% of other sector documents; first-of-kind equipment support appears in 5.3% vs 0.8%. The language is most frequent in future-industry (19%), hydrogen (16%) and AI (17%) documents. Hand check: 39/40 sampled matches are genuine.
2. In machine tools and robots, the trade data look like substitution at work; in chip-making tools, not yet. China exported $0.21 of machine tools for every dollar imported in 2012, and $1.42 in 2025; machine-tool imports are 56% below their 2012 peak. Robots went from 0.16 to 0.97. Chip-making equipment imports reached a record $50bn in 2025; China still buys about $9 of tools abroad for every dollar it sells.
3. Switzerland is exposed, and so far has held its ground. Excluding gold, Swiss goods exports to China were $17.0bn in 2025; 51% of that is in the exact product lines China targets for substitution (mostly medicines). Switzerland's share of China's pharmaceutical imports rose from 5.0% in 2018 to 9.4% in 2025, and of machine-tool imports from 3.3% to 5.2%: substitution has hit mid-market suppliers first. The pressure ahead is category-wide: volume-based procurement of medicines, the 2026 domestic-product price preference in public procurement (hospital equipment is public procurement), and first-of-kind support for domestic equipment.
4. Provinces take up most central directives, within months. 59% of State Council directives (2013–2025) are restated within a year by at least one of six provinces whose government documents are listed in full (653 of 1,112), a median of 151 days after the directive (middle half 84–259 days). Whether provinces respond less often than a decade ago is not established: a pre-registered test puts 2022–25 directives at about 40% fewer responses within a year than 2013–15 ones, but the interval reaches no change (ratio 0.61, 95% interval 0.28–1.07; reports/pap_responsiveness_results.md).
5. The 15th Five-Year Plan names the next targets. In the first 271 15th-plan documents, compared with 501 from the 14th plan, these sectors are named markedly more often: future industries 12% → 23%; low-altitude economy 19% → 28%; equipment renewal and trade-in 6% → 14%; biomanufacturing and the bioeconomy 3% → 7%. These are where the next round of local subsidies, guidance funds and procurement preferences will appear.
What it means
- For trade policy: substitution is now a stated, funded objective in local rules. Disciplines on subsidies and procurement (WTO, the EU's instruments, FTA upgrades) bite on the local layer, which is where the evidence is.
- For exporters: the risk is less a tariff than a category rule: a procurement preference or a first-of-kind programme that applies to a whole product line. Swiss and EU firms at the top of their ranges have held share so far.
- For monitoring: watch the provinces and the sector trees, not only Beijing. The first local rule under an industrial root is the signal that money is about to move.
How we know
- Documents: State Council and ministry libraries (gov.cn), the government portals and gazettes of all 31 provinces and their cities, with archive copies (Common Crawl, the Wayback Machine) where a portal no longer serves them, linked by their own citations (发文字号 and titles) into sector trees.
- Measures: our own PRC instrument taxonomy, screened from each document's text, each with its quote; stated rationale per measure, also quoted.
- Trade: UN Comtrade, China and Switzerland as reporters, HS 6-digit and 4-digit lines.
- Validation: 39/40 substitution matches and 40/40 directive responses confirmed by hand. All data behind the charts can be downloaded.
Limits
- Every province has at least 100 local documents, but only six provinces' government documents are listed in full; the rest are partial.
- Trade movements are consistent with the policy, not proof that it caused them.
- The 15th-plan comparison rests on the first plans out; the full set arrives through 2027.
- Measures in attachments of the newest documents are not yet screened.