Shoppers browsing MediaMarkt or Saturn are caught in a regulatory clash. China has ordered its firms to stop helping an EU probe into a Chinese takeover of the German retail chain. The outcome could decide the fate of more than 1,000 stores across Europe.

JD.com is China’s largest ecommerce retailer by sales. It launched a €2.2bn bid for Ceconomy in July last year. At the time, the deal was billed as one of Beijing’s largest investments in Europe in recent years. Ceconomy runs Saturn and MediaMarkt stores across several EU countries. Millions of shoppers use them every year.

The deal was expected to close in the first half of 2026. Instead, the European Commission opened an in-depth investigation in May into whether unfair Chinese subsidies helped JD.com win the bid. Brussels must now decide by 23 October whether the takeover can proceed. The original deadline was extended after JD.com submitted proposed commitments on 18 August, one day before China’s order to its firms.

A tool built for such cases

The investigation runs under the EU’s Foreign Subsidies Regulation (FSR). This is a relatively new competition tool. It lets Brussels check whether state support gave foreign companies an unfair edge when buying EU assets. Firms under scrutiny must hand over detailed information, often fast. The Commission could still clear the deal, block it, or accept commitments from JD.com.

This is an undue demand on the entity and a serious violation of international rule of law. — Spokesperson, China’s Ministry of Justice

China’s Ministry of Justice rejected the probe in a joint statement with the Ministry of Commerce. It called the investigation an act of “undue extraterritorial jurisdiction measures”. A ministry spokesperson accused Brussels of “arbitrarily demanding extensive and unnecessary information about China”. “This is an undue demand on the entity and a serious violation of international rule of law,” the spokesperson said.

Beijing could retaliate “in accordance with the law” if Brussels persists, the spokesperson added. The clash lands amid wider strain between the two blocs. Brussels is already probing Chinese ecommerce platforms under the Digital Services Act. It has also targeted steel and duck imports with anti-dumping measures. A new law would push companies to diversify supply chains away from China.

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A Commission spokesperson defended the approach. The regulation, they said, “does not distinguish between companies based on their nationality or ownership”. JD.com declined to comment on the Chinese order or the investigation.

Not the first flashpoint over subsidies

This is not the first time a Chinese company has pushed back against the FSR. Wind turbine maker Goldwind asked last month for its own case to be suspended. It argued the Commission had gone beyond the scope of its investigation. The EU’s General Court rejected the request, calling it too speculative.

For JD.com, the Chinese order creates a genuine dilemma. As the newsletter Geopolitechs put it: giving information to the Commission could breach the Chinese ban. Withholding it could make investigators conclude the company failed to cooperate.

China has stopped short of demanding the investigation be dropped. Its objection targets one point: the Commission’s request for information held inside China. Whether that argument slows the case, or hardens both sides’ positions, should become clear before the October deadline.