MOFCOM, China's Ministry of Commerce, published on 2 May 2026 the five Chinese refineries protected under its Blocking Rules order: Hengli Petrochemical (Dalian), Shandong Shouguang Luqing, Shandong Jincheng, Hebei Xinhai Chemical, and Shandong Shengxing.1 The activation of the 2021 Blocking Rules was already documented; the public identification of the five protected entities is the new beat.
The Blocking Rules are China's 2021 statutory instrument allowing Chinese parties to defy extraterritorial foreign sanctions and recover damages through Chinese courts. The order forbids the named refineries from complying with OFAC's Iran sanctions regime, which had previously designated Hengli Petrochemical under sanction package SB0472 with a General Licence V wind-down. Hengli alone runs 400,000 barrels per day at Dalian, making it China's second-largest independent refinery; it is also the most exposed of the five to OFAC secondary-sanction action, which is why MOFCOM placed it at the top of the list.
The named list creates two operational facts. First, the protected refineries can now legally process Iranian crude under Chinese law without exposure to civil liability inside China for the same activity that creates US sanctions exposure. Second, the OFAC enforcement counterparty is now identified; any further US designations under the GL-W toll alert will hit named entities the Chinese state has explicitly placed under protection, raising the diplomatic cost of each new designation. The four other refineries, all Shandong or Hebei independents, sit further down the OFAC priority list and were probably named to spread the political cost of the carve-out beyond a single flagship plant.
The sequencing matters. MOFCOM published the names on the same Sunday Trump announced Project Freedom and Pakistan delivered the first US written reply. The Chinese counter-sanctions architecture is now visible at the entity level for the first time since the war began; the next OFAC tier of designations against named recipients, charity rails, embassies, or FX houses, will land in a clearer Chinese counter-frame than any previous round.
