China Pharma & Biotech: Policy headwinds and implications forvaluation We review recent US and China policies - a trigger of the recent healthcare sell-off - andestimate the potential impact on innovative drugmakers in this note. Rebecca Liang, Ph.D.+852 2123 2656rebecca.liang@bernsteinsg.com US policies and legislative efforts (Biosecure Act, COINS/BINSA) increasingly target thefull stack: capital flows, data access, licensing, and supply chains. While implementationremains staged, the direction is unambiguous and calls forreduced US capitalparticipation, tighter scrutiny on cross-border deals, and rising friction incollaboration. This shift matters because the US still anchors global pharma economics,representing ~50–60% of commercial value, and therefore sets the ceiling for any globally Ellie Li+852 2123 2621ellie.li@bernsteinsg.com Recently, a simplified narrative of China’s rapid rise in biopharma is becoming increasingcommon. We see a more nuanced picture: the innovation engine continues to scale rapidly,but remains structurally front-loaded. China now accounts for a meaningful share of globalearly-stage activity (~30–40% of preclinical, ~50% of early clinical pipelines, and ~55% offirst clinical trial registrations in 2026 YTD), reflecting genuine improvements in researchcapability and development speed.However, the rise has not translated proportionallyinto late-stage presence yet, where the ecosystem remains US-centric.China-origin assets still represent only a small share of US Phase 3 trials (<10%), FDA approvals(<5%), and US commercial sales (~1%), albeit with gradual improvement.We attributethis to two factors: 1) a time lagas the recent acceleration in outbound deal-making Our scenario analysis highlights how sensitive that value bridge is to policy. Under an “indirect access” case where the US market remains open to China-origin assetsthrough collaborators in EU, Japan, etc., we assume BD (Business Development) incomedeclines ~50% and global peak sales ~20% as routes become more difficult. Under a“complete block” where the US market is effectively off-limits, BD income falls ~80%and global sales ~60%, implying a much sharper reset with value largely confined to ex-USmarkets. The key implication is the equity impact:in a full block, globally exposed namessuch as Innovent, Hengrui, and Hansoh could see ~50% downside to valuation(Exhibit 11).Kelun looks the most resilient as its flagship product sac-TMT is the mainvaluation anchor, and is relatively derisked with competitive data and 17 US trials on-going. BERNSTEIN TICKER TABLE INVESTMENT IMPLICATIONS We rate Hansoh, Jiangsu Hengrui, Kelun-Biotech, BeOne Medicines, and Innovent Outperform; and Akeso, Zai Lab, SinoBiopharm, and CSPC Market-Perform. DETAILS COMBING THROUGH RECENT POLICIES RELATING TO CHINA HEALTHCARE US policies tighten on both inbound market access and outbound capital flowAcross recent administrations, US policy has introduced a range of measures affecting China’s biopharmaceutical sector, oftenwithin a broader national security and supply chain framework. Policies and EOs: February 2025 – America First Investment Policy:At the strategic level, the “America First Investment Policy” (a presidentialmemorandum signed under the Trump administration) stresses a high-level stancelimiting both inbound and outbound April 2025 – NSCEB report:At the architectural level, the NSCEB (National Security Commission on Emerging Biotechnology)report serves as a policy advisory framework and, at a strategic level, aiming to constrain China’s biopharma development. January–September 2025 – Early outbound controls:Initial measures includedrestrictions on access to certain USdatasets(e.g., NIH-related data) and indications of tighter oversight on cross-border licensing and supply chain localization. Legislation: June 2026 - COINS and BINSA:The introduction of BINSA (Biotech Investment National Security Act), as part of the broaderCOINS Act framework, further escalates restrictions. The proposal includes mandatory governmentreview of cross-borderlicensing transactions, tighter scrutiny on US-China joint ventures, and limits on equity investments involving Chinesebiopharma companies. Notably, recent transactions - including Innovent/Pfizer and Hengrui/BMS collaborations (Pfizer and 2023–2026 – Biosecure Act:The Biosecure Act restricts US federal agencies and federally funded entities from sourcingbiotechnology products or services from designated “biotechnology companies of concern” (BCCs). Importantly, federalfunding encompasses programs such as Medicare/Medicaid, which are deeply embedded in the revenue base of large MNCs.Therefore, MNCs may need to avoid engaging designated Chinese CDMOs. As such, the Biosecure Act could drive a structuraldecoupling between Chinese CDMOs and Western pharma. While certain companies (e.g., WuXi AppTec, WuXi Biologics, both Looking ahead, there’s plenty to watch on BINSA and Biosecure Act.1) BINS