Written submission from Russ Wilcox (CHI0021)

HOUSE OF COMMONS

BUSINESS AND TRADE COMMITTEE

Inquiry: China and the UK Economy

What China’s Own Documents Reveal

About Its Economic Approach to the United Kingdom

A Primary-Source Analysis of the PRC’s 15th Five-Year Plan, the Ministry of Commerce UK Investment Guide, and Chinese Corporate Regulatory Filings

Russ Wilcox

CEO, ArtifexAI · Editor, The Pacific Divide · Policy Chairman, American Society for AI

Research Assistant: Ryan Locher

Classification: Open Source / Unclassified

Source documents: PRC 15th Five-Year Plan (NPC, March 2025); MOFCOM Country Guides—UK, Australia, Canada; Tongfu Microelectronics CSRC filing (March 2016); Yutong Bus/Heavy Industries SSE filings

Methodology: Structured open-source document exploitation of Chinese-language primary sources

Introduction

1.              I am the CEO of ArtifexAI, Policy Committee Chairman of the American Society for AI, and Editor of The Pacific Divide, a publication on US–China technology competition. I have published primary-source analysis of Chinese technology strategy in The Diplomat and the Jamestown Foundation’s China Brief (April 2026), and have briefed members of the United States Congress, federal agencies, and allied governments on China’s AI infrastructure strategy.

2.              This submission concentrates on data security risks from Chinese-connected technologies (Section 7 of the call for evidence), control of strategic technologies (Section 6), supply chain security (Section 3), and international comparators (Section 8). It does not attempt to address all eight sections.

3.              The methodology is as follows. I read two PRC government documents side by side: the 15th Five-Year Plan[1] and the MOFCOM UK Investment Guide (2023 edition, published April 2024).[2] The observations below emerge from reading these documents as a pair, supplemented by Chinese-language corporate regulatory filings, securities research, PRC legislation, and Belt and Road programme documentation. All sources are open-source and verifiable.

The Strategic-to-Operational Pipeline

4.              The Five-Year Plan sets out what China intends to develop and acquire. The MOFCOM UK Investment Guide maps where those things can be found in the United Kingdom, what incentives are available, and how the UK’s screening mechanisms work. When the two documents are read together, the alignment is notable. The FYP names priority technology sectors including integrated circuits, AI, biotechnology, green hydrogen, and robotics. The MOFCOM guide, separately, catalogues UK enterprise zones by name alongside their sector specialisations and applicable tax incentives. A Chinese enterprise reading both documents receives what amounts to a pre-matched target list: the FYP identifies the sector to pursue; the MOFCOM guide identifies the specific UK zone that offers incentives in that sector, down to the URL and local government contact.

5.              This is not inherently improper. Investment promotion is a standard function of trade ministries. What distinguishes this guide is the specificity of the targeting and the absence of any countervailing information about UK security mechanisms that apply to these same sectors.

The Omission Pattern

6.              The MOFCOM UK guide documents the National Security and Investment Act 2021 and the Economic Crime Act in substantial detail, reproducing NSI Act screening thresholds including the 17 mandatory notification sectors.[3] It does not mention UK dual-use export controls, the Academic Technology Approval Scheme, semiconductor export restrictions, MI5 public warnings about Chinese economic espionage, or the Intelligence and Security Committee’s 2023 China Report. These omissions are notable because the sectors targeted in the enterprise zone mapping are precisely those subject to heightened scrutiny under the instruments the guide does not mention.

7.              The Five-Year Plan, read alongside these omissions, sharpens the concern. Chapters 55–56 of the FYP direct the establishment of “green channels for frontier science and technology achievements to enter military use” and call for “efficient fusion of new productive forces and new combat forces, with bilateral pull.” A guide that covers the NSI Act and Russia sanctions compliance in substantial detail but omits the UK’s primary mechanisms for preventing dual-use technology transfer is difficult to explain as a simple gap in coverage. The omission sits uneasily with the guide’s own stated purpose of helping Chinese enterprises “effectively prevent and resolve various risks.”

The Legal Compulsion Framework

8.              Three laws enacted between 2017 and 2021 create a compulsory cooperation regime for any Chinese organisation or citizen. The National Intelligence Law (2017), Article 7, requires any organisation and citizen to “support, assist, and cooperate with national intelligence work.”[4] The Cybersecurity Law (2017), Article 28, requires network operators to provide technical support and assistance to public security and national security organs.[5] The Data Security Law (2021), Article 35, requires organisations and individuals to provide data to public security and national security organs upon request.[6] Refusal is punishable by detention or criminal prosecution.

9.              This legal triad means that any data collected by a Chinese manufacturer’s connected technology platform is accessible to Chinese intelligence services on demand. The MOFCOM UK guide does not mention these laws. It omits both what the UK does to screen Chinese activity and what Chinese law requires of Chinese entities operating abroad.

Layer 1: Connected Vehicles and the PLA Corporate Structure

10.              Yutong Bus Co., Ltd. (SSE: 600066) is China’s largest bus manufacturer, exporting to over 40 countries including the United Kingdom. Its 2024 Annual Report discloses a centralised cloud platform called Anruitong connecting over 390,000 vehicles worldwide.[7] The report identifies core functions including vehicle monitoring, driver behaviour analysis, remote vehicle control, and remote software upgrades. Platform data “efficiently feeds back into vehicle R&D and design” at Yutong headquarters in Zhengzhou.[8]

11.              Yutong Bus is one half of a corporate pair. Shanghai Stock Exchange filings confirm that Zhengzhou Yutong Group Co., Ltd. is the controlling shareholder of both Yutong Bus (41.72 per cent) and Yutong Heavy Industries Co., Ltd. (SSE: 600817, 68.56 per cent).[9] Both companies share the same ultimate beneficial owner. Yutong Heavy Industries is a state-designated manufacturer of military and civilian engineering machinery. It holds military production qualification, has produced three generations of military bulldozers and over 20 types of military machinery for the People’s Liberation Army, and its military production line was personally inspected by the Vice Chairman of the Central Military Commission.[10] The same corporate family that exports connected buses to UK public transit manufactures equipment for the PLA.

Figure: Yutong corporate structure from Shanghai Stock Exchange regulatory filings. Same parent company, same ultimate beneficial owner. The bus exporter and the PLA contractor are sister companies under unified control.

12.              Danish security services identified Yutong electric buses in Danish public transit as containing embedded communications modules transmitting data to a Chinese-operated server.[11] Denmark has among the strongest data privacy frameworks in Europe. The data architecture arrived as a product before anyone identified it as infrastructure. Under the legal compulsion framework described above, any data on the Anruitong platform is accessible to Chinese intelligence services. The MOFCOM Denmark guide explicitly warns Chinese enterprises that Danish screening criteria include “whether the supplier is directly or indirectly controlled by a foreign government or military.”[12] The MOFCOM UK guide omits the equivalent UK mechanisms.

Layer 2: Permanent Technology Transfer at the Packaging Layer

13.              In March 2016, Tongfu Microelectronics filed a 242-page acquisition report with the China Securities Regulatory Commission disclosing that AMD had granted a “non-exclusive, worldwide, fully paid-up, royalty-free, non-transferable, permanent, and irrevocable licence” covering CPU, GPU, and APU packaging intellectual property.[13] The buyer was capitalised by China’s National IC Industry Investment Fund with $270 million. No CFIUS review was conducted. Five months earlier, a parallel state-backed acquisition secured STATS ChipPAC, a Singaporean advanced packaging company whose customer base was 68 per cent American. The fund deployed nearly twice the capital into the transaction that included permanent IP.[14]

14.              The strategic significance is architectural. China has constructed two chip-agnostic layers in the semiconductor stack: permanent packaging capability below the chip, and software abstraction platforms above the chip that route workloads to whatever processor is available. The chip becomes the interchangeable component in the middle. The October 2022 export controls, and the UK’s aligned restrictions, target fabrication and advanced chips. They do not target packaging. They do not reach IP that was permanently transferred by contract a decade earlier. The MOFCOM UK guide’s omission of semiconductor export restrictions is consistent with this pattern: the guide documents the screening mechanisms that Chinese enterprises must navigate while omitting the controls that constrain the technology domains where China has already secured permanent capability.

Layer 3: The Belt and Road Institutional Capture Model

15.              The same architectural pattern operates at the institutional layer. China’s Belt and Road science cooperation programme deploys across 23 countries positioned at global maritime chokepoints including the Suez Canal, Strait of Malacca, and Cape of Good Hope.[15] The programme follows a documented three-stage model: initial engagement through low-barrier research projects; institutional lock-in through joint laboratories requiring ministerial approval and Chinese equipment installation; and strategic dependency through mandatory membership in Chinese-led alliances. IP ownership protections, data sovereignty provisions, vendor independence pathways, and exit clauses are systematically absent at every stage.

Figure: Belt and Road 2025 Science Cooperation Programme deployment across 23 countries. Tier 1 countries are positioned at global maritime chokepoints. Total: 75 projects, 4.7 billion records/year data capacity, drone deployment in 13 countries.

16.              The relevance to the UK is structural, not geographic. The MOFCOM UK guide maps the same entry mechanisms operating through different channels. The FYP’s energy transition targets appear to be roughly double the UK’s in comparable categories—China does not need UK energy. What the MOFCOM guide documents it values in the UK is London’s green bond market, the Green Investment Principles secretariat headquartered jointly in London and Beijing, TCFD-aligned disclosure standards, and the mechanics of Contracts for Difference auctions. The UK needs Chinese manufacturing capacity to meet its legally binding net zero commitments. China appears to need London’s financial architecture to legitimise its clean-energy export ecosystem globally. This creates structural dependency with an asymmetry: the UK has less manufacturing redundancy than China has alternative financial centres.

The Connecting Pattern

17.              The committee’s inquiry addresses data security, technology transfer, supply chains, and investment screening as separate policy domains. These three cases suggest they are layers of a single architecture. At the product layer, infrastructure arrives as a bus and embeds data collection and remote control. At the technology layer, infrastructure arrives as a commercial acquisition and embeds permanent capability transfer. At the institutional layer, infrastructure arrives as development assistance and embeds strategic dependency. At every layer, the common feature is that critical protections—IP ownership, data sovereignty, vendor independence, exit clauses—are systematically absent from the terms of engagement. And the MOFCOM UK guide is the operational document connecting all three layers: it maps the enterprise zones where product-layer investments land, omits the export controls that would constrain technology-layer transfers, and maps the green finance architecture through which institutional-layer dependency flows.

Figure: The technology stack and export control coverage. Export controls target fabrication—the interchangeable layer in the middle. China holds permanent capability at the layers above and below.

Subnational Vulnerability

18.              The MOFCOM guide’s detailed regional coverage—Northern Powerhouse, Midlands Engine, individual enterprise zones with URLs and contact information—constitutes a prioritised list of where scrutiny is lightest relative to incentives. Enterprise zones are administered by local authorities, combined authorities, and devolved administrations. These bodies have investment promotion mandates. They do not typically have the intelligence resources, Chinese-language analytical capacity, or security screening expertise to evaluate the strategic implications of inbound Chinese investment in the sectors the guide targets. The committee’s call for evidence asks how the UK Government can ensure a “whole-of-UK approach.” The MOFCOM guide suggests that Chinese investment strategy already takes a whole-of-UK approach. The question is whether the UK’s defensive architecture matches it.

MOFCOM Comparative Analysis across Five Eyes

19.              Examination of the MOFCOM guides for Australia (2024 edition) and Canada (2024 edition) indicates that the omission pattern is not UK-specific. The Australia guide documents FIRB, the Critical Infrastructure Security Act, and national security review powers across 31 references to national security. The Canada guide is the most detailed of the three, with 64 national security references, and explicitly describes Canada’s posture toward Chinese investment as “increasingly restrictive.”

20.              All three guides omit military-civil fusion, technology transfer restrictions, and data security obligations. The Canada guide is the only one that mentions export controls. The core omissions persist across all three countries regardless of the strength of the host country’s screening architecture. Minor variations between the guides make the pattern more credible, not less: each guide is customised to its host country’s regulatory landscape, yet the same categories of information are systematically excluded.

Figure: MOFCOM investment guide omission matrix across three Five Eyes countries. Verified by full-text search of Chinese-language PDFs. Core omissions persist across all three countries. Minor variations indicate customisation, not a blind template.

21.              I recommend the committee consider commissioning the extension of this analysis to the remaining Five Eyes and G7 partners. The MOFCOM guides are publicly available in Chinese and follow a standardised format. The analytical methodology is directly replicable. A three-country pattern is strong. A Five Eyes pattern would be definitive. This work could be conducted as a joint allied analytical project, and the UK is well positioned to propose it.

Limitations and Caveats

22.              The MOFCOM guide is one document in a much larger Chinese investment advisory ecosystem. Its omissions may reflect editorial conventions, word limits, or target audience assumptions rather than deliberate strategic direction. The mundane explanation—that an investment guide emphasises opportunities over risks—deserves weight. The alignment between the FYP and MOFCOM guide may be a product of bureaucratic coherence rather than explicit coordination. The practical effect for a Chinese enterprise reading both documents, however, is similar either way.

23.              The Yutong cloud platform evidence is drawn from the company’s own regulatory filings to the Shanghai Stock Exchange and from Chinese-language securities research. The 2024 Annual Report describes capabilities and stated purposes; it does not constitute proof of data exfiltration. The corporate relationship to Yutong Heavy Industries is documented in SSE filings and company disclosures but does not prove intelligence coordination between the bus manufacturer and the military equipment manufacturer.

24.              The Denmark case is referenced from discussions with UK parliamentary staff. The committee may wish to verify through diplomatic channels with the Danish government. The semiconductor packaging analysis describes a design intent, not a completed capability; China’s software abstraction layer is not yet competitive with NVIDIA’s CUDA ecosystem for frontier AI training workloads. The Five Eyes comparative finding is based on three countries; the recommendation to extend the analysis reflects the value of a larger sample.

25.              I am an American citizen and consultant with no financial interest in UK–China trade outcomes. My analysis is based on Chinese-language primary sources read in the original.

Oral Evidence

26.              I am prepared to give oral evidence to the committee on any of the matters addressed in this submission, including live demonstration of the Chinese-language primary source analysis methodology, the MOFCOM comparative framework, and the Yutong corporate structure analysis with reference to the original Shanghai Stock Exchange filings.

Primary Sources Cited

Publications by the Author

•  Wilcox, R. “China’s 5-Year Plan Has Moved Beyond the Chip War. Washington Hasn’t Noticed.” The Diplomat, 10 March 2026.

•  Wilcox, R. “The Chip Packaging IP That Export Controls Cannot Reach.” China Brief, Jamestown Foundation, 7 April 2026. https://jamestown.org/the-chip-packaging-ip-that-export-controls-cannot-reach/

PRC Government Documents

•  Outline of the PRC 15th Five-Year Plan for National Economic and Social Development and Long-Range Objectives Through 2035. Adopted by the 14th NPC, March 2025.

•  Ministry of Commerce, Country Guide for Outbound Investment Cooperation: United Kingdom. 2023 edition, published April 2024.

•  Ministry of Commerce, Country Guide for Outbound Investment Cooperation: Australia. 2024 edition.

•  Ministry of Commerce, Country Guide for Outbound Investment Cooperation: Canada. 2024 edition.

•  Ministry of Commerce, Country Guide for Outbound Investment Cooperation: Denmark. 2024 edition.

•  National Intelligence Law of the PRC. Promulgated 27 June 2017, amended 27 April 2018.

•  Cybersecurity Law of the PRC. Effective 1 June 2017.

•  Data Security Law of the PRC. Effective 1 September 2021.

•  Ministry of Science and Technology, Belt and Road Strategic S&T Innovation Cooperation Special Project 2025 Annual Application Guide. Beijing, 2025.

•  State Council of the PRC, State Council Gazette No. 25. September 2025.

Chinese Corporate and Regulatory Filings

•  Tongfu Microelectronics Co., Ltd., Report on the Acquisition of AMD Assembly Operations. CSRC Filing, 25 March 2016, 242 pp. http://static.cninfo.com.cn/finalpage/2016-03-25/1202074501.PDF

•  Yutong Bus Co., Ltd., 2024 Annual Report. Shanghai Stock Exchange: 600066.

•  Yutong Heavy Industries Co., Ltd., Q3 2024 Report. Shanghai Stock Exchange: 600817.

•  Yutong Group tender offer report, 2023. Disclosing ultimate beneficial owner and ownership structure.

•  AMD, Form 8-K. U.S. Securities and Exchange Commission, 15 October 2015.

•  China Investment Securities, “JCET: STATS ChipPAC Acquisition Raises Advanced Packaging Capability.” Analyst report, 2 November 2015, 13 pp.

•  Guosen Securities, equity research report on Yutong Bus (600066.SH). 31 March 2026.

•  Soochow Securities, “Yutong Bus: Domestic and International Resonance, A Belt and Road Exemplar.” 27 April 2023, 39 pp.

Other Sources

•  Bureau of Industry and Security, U.S. Department of Commerce. OSAT facility whitelist provisions. Federal Register, January 2025.

•  Yutong Heavy Industries corporate description. Tiejia Engineering Machinery Network, November 2021.

•  CMC Vice Chairman Zhang Youxia inspection of Yutong Heavy Industries military production line. Yutong corporate news release.

All MOFCOM country guides are available at http://fec.mofcom.gov.cn/article/gbdqzn/. Full Chinese-language text of all cited documents can be provided to the committee upon request.

April 2026

Russ Wilcox

CEO, ArtifexAI · Editor, The Pacific Divide · Policy Chairman, American Society for AI

Research Assistant: Ryan Locher

The author is available to provide oral evidence, additional written submissions, or comparative analysis of MOFCOM guides for other countries of interest to the committee.

— End of Submission —