In January, 2026, the Shanghai Municipal Development and Reform Commission, the Municipal Commission of Commerce, and nine other departments jointly issued the Several Measures for Encouraging Domestic Reinvestment by Foreign-Invested Enterprises in Shanghai.

This policy document, dubbed the "20 Measures for Reinvestment by Foreign Enterprises," comprises 20 specific measures designed to attract and utilize foreign capital with greater intensity, encouraging foreign-invested enterprises to deepen their development in China.

The introduction of the "20 Measures" was no coincidence. Domestic reinvestment by foreign-invested enterprises has become an important mode of foreign investment in recent years.

Following extensive consultations with foreign enterprises and relevant business associations, the Shanghai Municipal Development and Reform Commission and the Municipal Commission of Commerce formulated this systemic policy measure in light of the city's actual conditions.

The "20 Measures" establish a comprehensive policy support framework across four dimensions: promoting project implementation, facilitating investment and operations, implementing tax policies, and optimizing investment promotion.

The new policy achieves significant breakthroughs in broadening financing channels. Most notably, it removes restrictions on foreign-invested holding companies using domestic loans, explicitly permitting them to use such loans for equity investment.

This change opens new financing avenues for foreign-invested enterprises. The policy also supports foreign-invested enterprises in leveraging facilitation measures for medium- and long-term foreign debt review and registration when applying for loans from foreign parent company affiliates.

Another important innovation is the support for parent companies of foreign-invested enterprises to issue "Panda Bonds" in the interbank and exchange markets, with proceeds used for domestic reinvestment.

From international capital markets to domestic banking systems, and to enterprises' own profits, foreign-invested enterprises now enjoy comprehensive financial support for domestic reinvestment.

Land supply and usage policies are critical considerations for enterprises expanding reinvestment. The "20 Measures" provide substantive support in this regard.

The policy introduces a "20-year flexible term + renewal upon application" system for industrial land, and encourages flexible land use methods such as lease-first-then-transfer, lease-and-transfer combination, and long-term leasing.

For major foreign investment projects at the national and municipal levels, special policies allow industrial land to be granted for a 50-year term, significantly reducing long-term land costs for enterprises.

Furthermore, for foreign-invested enterprises with technological transformation needs, the policy explicitly supports their applications for national ultra-long-term special treasury bonds to carry out large-scale equipment upgrade investments in key areas.

The policy introduces a series of facilitation measures targeting specific sectors such as healthcare and food, reflecting a refined management approach.

For the medical device industry, the product transfer process has been simplified: foreign-invested enterprises transferring production of Class II medical devices already holding import registration certificates to Shanghai may be exempted from on-site inspections of registration and production quality management systems.

In pharmaceutical wholesale, a "multi-warehouse collaboration" mechanism has been introduced, allowing foreign-invested pharmaceutical wholesale enterprises with unified quality management systems to share warehousing, transportation, and other resources for cross-regional collaborative logistics activities.

Food chain enterprises also benefit: eligible foreign-invested chain food retail enterprises may be exempted from on-site inspections when applying for new food business licenses for outlets.

Regarding service sector opening-up, the "20 Measures" provide broader space. The policy explicitly supports eligible foreign-invested enterprises in participating in national comprehensive pilot programs for expanding service sector opening-up.

Specifically, foreign-invested enterprises may reinvest in expanded opening-up sectors including value-added telecommunications, healthcare, biotechnology, culture, education, and finance, providing policy assurance for foreign enterprises to deepen their presence in these key service sectors.

Meanwhile, the policy encourages foreign-invested enterprises to shift imported products to domestic production and supports their participation in pilot programs for cross-border segmented production of biological products, reflecting particular attention to high-end manufacturing and biomedicine.

In R&D and innovation, the policy supports foreign-invested enterprises in reinvesting to establish R&D institutions, building municipal-level key laboratories and technology innovation centers, and enjoying relevant support policies in accordance with the law.

Foreign enterprises should assess whether their industry and investment plans "match" the policy scope, particularly in specific sectors such as pharmaceuticals and food.

Enterprises with existing investment plans should examine whether they can leverage the new financing policies.

Policy implementation requires professional interpretation; enterprises may consult professional investment advisory institutions to obtain customized solutions.