Report Outlines Policy Changes for China
Published: Friday, December 12, 2025
America First Policy Institute Vice Chair of Rural Policy Kip Tom, former ambassador to Rome and Leesburg farmer, along with Royce Hood, AFPI policy analyst, last month released a report identifying China's acquisition of key players in the U.S. agricultural economy and encouraging policy reform around farmland and intelligence securi-ty.
The report provides exclusive research on how once-American companies, such as Smithfield and Syngenta, have been acquired or are effectively controlled by Chinese state-owned enterprises.
The purpose of the policy recommendations is to "put a lens around intellectual property" and "create accountability for using data to benefit the CCP," Tom said in an interview with the Exchange.
Tom and Hood recommend the following policies be enacted:
Committee on Foreign Investment in the U.S. (CFIUS) review and re-evaluation.
"CFIUS should re-review the purchases of both Syngenta and Smithfield – and any Chinese SOE (state operated enterprises) purchases -with special consideration for market consolidation, food securi-ty, national security risks, and threats to proprietary information and consumer data," Tom and Hood wrote.
They identified several examples of market manipulation attributed to Smithfield in their report. Tom and Hood added that Smithfield reportedly favored exporting pork to China rather than selling products domestically during a nationwide shortage in the U.S. during COVID.
Tom and Hood also said the acceleration of the filing process through the application of declaration, also known as short-form expedition, with CFIUS should be prohibited for all adversarial countries.
Tom doubts a second CFIUS review will take place, due to the imbalance that could create in the market with investors.
Much of the needed changes, according to Tom, must be brought about by the Department of Justice.
In order for this to happen, "we've got to get the attention of Congress. That's taking place, and we're helping them understand that it's a part of national securi-ty," Tom said.
Mandatory Foreign Agents Registration Act (FARA) registration.
"Syngenta, owned by a CCP-controlled company ChemChina, lobbies key federal agencies ... These and other CCP-affiliated com-panies pose a serious and ongoing threat to U.S. national security, food supply chains, and economic prosperi-ty," Tom and Hood wrote.
The authors noted that under Chinese influence, Syngenta and Smithfield are subject to the National Intelligence Law of 2017 and the Data Security Law of 2020. These mandate compliance and sharing of data with Chinese security and intelligence agencies.
"The PRC is keenly aware that the con-tinued productivity of the U.S. agricultural sector is crucial for American prosperity and food security. Chinese SOEs' quiet acquisition of companies critical to the sector, such as Syngenta and Smithfield, provides an important avenue for PRC malign influence," Tom and Hood reported.
Tom and Hood stated that both Syngenta and Smithfield "routinely" fail to register as foreign entities while lobbying U.S. agencies. They qualify this as suspect due to the obligations the two companies have to China.
"If we go back in time everyone thought China was buying Smithfield to make up for shortages in their swine production," Tom said. "But they were buying it for its intellectual property."
He added, "The CCP has made it illegal if a com-pany doing business in China, if they acquire intellectual property (and) if they don't turn that in to the CCP, they are violating the law."
They conclude that all Chinese-owned businesses should be considered agents of a foreign government for FARA, and should be mandated to register.
"Companies that are principally Chinese in their operations or governance but are headquartered in third countries should be considered principally Chinese-operated and should also be required to register with the Department of Justic under FARA," they wrote.
Domestic divestiture.
"Chinese-owned agricultural companies now hold significant stakes in multiple sectors of the $1.5 trillion American agricultural industry, Tom and Hood wrote. "Smithfield, owned by the Chinese WH Group, controls one quarter of U.S. pork processing. This grants them market dominance, enabling them to set prices and establish industry standards."
They also reported that Syngenta, under the leadership of ChemChina, is a concern for monopolization of agricultural products. They noted that upon Chem-China's acquisition of Syngenta, The U.S. urged Syngenta to divest from a slew of pesticide products to avoid monopolization.
However, they also noted that Syngenta has continued to acquire biological companies, such as Valagro and Novartis, further consolidating the market.
Tom and Hood also expressed concerns about in-tellectual property theft and how China uses this information to push out international competi-tion.
"That insight gives them leverage in the marketplace to give themselves market domi-nance," Tom said.
He added that the CCP has digital platforms in several countries already, including Brazil, Argentina and Ukraine.
Tom and Hood said there are multiple examples of partnerships Chinese com-panies have made with international companies that resulted in the acquisition or liquidation of the partnering com-pany.
"When such arrangements, either openly or illicitly, have been exploited to their fullest extent, the CCP will then create its own self-sufficient and home-grown version to compete and ultimately eject foreign com-petition," Tom and Hood wrote.
They added that Smithfield and Syngenta are often favored by the People's Republic of China "and they may tailor their operations specifically to meet the needs of the PRC market."
"Syngenta is the largest producer of chemicals for agriculture in the U.S.," Tom said. "What if they decide to shut that off?"
"Both Syngenta and Smithfield Foods should be compelled to divest to a domestic company, or, at minimum, a company not principally managed by an adversary of the U.S.," Tom and Hood wrote.
Tom said divestiture is key to ensuring a fair market due to China's process for gaining intellectual property.
"Stealing it should not be an option," Tom said.
Enforcement of the Uyghur Forced Labor Prevention Act.
"Syngenta's subsidiary XJJYF Liaises with XPCC, which is named in the UFLPA's text as a principal perpetrator and continues to be listed as a violator of the UFLPA by the Department of Homeland Security," Tom and Hood reported. "Syngenta products should face importation bans or restrictions in the U.S."
A ban on Chinese Communist Party drones.
Tom and Hood urged preventative measures against the widespread use and adoption of Chinese-manufactured drones in the U.S. for agricultural purposes. They encouraged the enforcement of the Countering CCP Drones Act.
Protection of U.S. farmland.
The policy experts recommend the production of federal- and state-level legislation restricting foreign control of U.S. farmland, especially from adverse na-tions.
"It comes down to the states' local rule on something like that," Tom said.
Complete implementation of the National Farm Security Action Plan.
Tom and Hood concluded that China could use its influence in Smithfield and Syngenta to destabilize markets during economic crises or interna-tional conflicts, and their influence on their respective markets should be mitigated through divestiture, U.S. regula-tion and policy enforcement.
They added that the U.S. agriculture industry should be bolstered through the USDA National Farm Security Action Plan to prevent devastation by any possible adverse actions taken by China.
Tom and Hood call for an update to the Agricultural Foreign Investment Disclosure Act reporting methods to make them more timely and modernized to create an effective deterrent to violators.
They also encourage the evaluation of the supply chains within the agriculture industry for "excessive foreign reli-ance."
"Agricultural research enterprises, particularly with public funding, should have higher se-curity standards and provide more value to America's farmers and ranchers," they wrote.
Tom and Hood suggest that the USDA Animal and Plant Health Inspection Service scrutinize foreign importers more closely, es-pecially from adversarial nations, and that USDA should support agricultural firms in their efforts to ward off cyber at-tacks and online threats through their digital and operational infrastructures. Finally, they added that USDA should have increased funding and authority to provide research and infrastructure security within the agriculture sec-tor.
How these policies might affect farmers if implemented is dependent on the way Syngenta and Smith-field react to the changes, Tom said.
However, despite the risk, he said the policy reform is essential to ensure fair market play and fortify U.S. national security.
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