China’s First-Ever Use of Export Control List Against U.S. Defense and Tech Companies
China has increasingly used sanction lists to counter U.S. restrictions
On January 2, following a brief one-day New Year holiday, China’s Ministry of Commerce (MOFCOM) issued its No.1 announcement of 2025 sanctioning 28 U.S. companies by adding them to its “Export Control List” (出口管制管控名单).
The 28 U.S. firms listed encompass the core of the American military-industrial complex, aerospace, defense electronics, and missile research and production sectors. Most are major U.S. defense contractors or companies providing technical support, such as Lockheed Martin and Boeing Defense. Additionally, the list includes emerging U.S. high-tech security firms like L3 Harris and Anduril. Many of them have close ties to U.S. arms sales to Taiwan, including providing weapon systems, integrated laboratory research, equipment upgrades, and logistical support.
This also marks the first time in China’s history that the “Export Control List” has been used to target U.S. firms.
Since 2020, China has increasingly used sanction lists to counter U.S. restrictions. In 2020, MOFCOM introduced the "Unreliable Entity List," and in 2021, the Ministry of Foreign Affairs created the "Countermeasure List" under the Anti-Foreign Sanctions Law. The "Export Control List" is the latest addition.
Modelled after the U.S. Commerce Department’s “Entity List,” the “Export Control List” was introduced in China’s Regulations on Export Control of Dual-Use Items last October. According to the Regulations, MOFCOM may, based on its authority or suggestions and reports from third parties, include relevant entities (importers and end-users) involved in importing Chinese dual-use items on the control list under the following circumstances:
Violation of end-user or end-use management requirements
Examples include failure to adhere to declared purposes or designated users, intentional transfer, or misuse of relevant items.Activities that may endanger national security and interests
Broadly, this includes any actions that pose a substantial threat or harm to critical national security or interests.Use of dual-use items for terrorist purposes
Any involvement in terrorist activities, once discovered, results in immediate inclusion on the control list.
Even if the above three conditions are not met, importers or end-users may still be included on the control list if they engage in the following activities and thereby endanger China's national security and interests:
Use of dual-use items for the design, development, production, or use of weapons of mass destruction and their delivery systems;
Being subject to prohibitions or restrictions imposed by the Chinese government on relevant transactions or cooperation, such as:
Inclusion on the "Countermeasures List" by China's Ministry of Foreign Affairs under the Anti-Foreign Sanctions Law;
Inclusion on the "Unreliable Entity List" by MOFCOM under the Provisions on the Unreliable Entity List;
Or other similar sanctions or restrictive measures imposed by authorized departments in accordance with the law.
Once included on the control list, MOFCOM may take one or more of the following measures against the relevant importers or end-users, depending on the nature of their actions, the severity of the circumstances, and specific situations:
Prohibit transactions involving relevant dual-use items
Fully sever transaction channels, preventing entities from obtaining or using controlled dual-use items.Restrict transactions involving relevant dual-use items
Impose restrictions based on quantity, type, application scope, time period, or other conditions.Order the suspension of exports of relevant dual-use items
Directly halt or cancel export activities related to projects that have not yet been completed.Other necessary measures
Depending on the specific case, these could include supervision, audits, technical restrictions, suspension of cooperation, and other enforcement actions.
Export operators are prohibited from engaging in transactions involving relevant dual-use items with importers or end-users listed on the control list in violation of regulations. In special cases where such transactions are necessary, the export operator shall apply to the MOFCOM and, upon approval, may conduct the transactions with these entities while reporting as required.
Meanwhile, if an entity is already on the "Watch List" stipulated by Article 26 of the Regulations and subsequently engages in violations or harmful activities, it may be put on the Export Control List. Conversely, if circumstances change in the future, the entity may apply for removal from the control list following the relevant procedures. Entities included on the “Watch List” are primarily there because they failed to cooperate with MOFCOM's verification or provide the required documentation within the specified timeframe, making it impossible to verify the end-user or end-use. Again, the "Watch List" is like a Chinese version of UVL.
Notably, companies listed can apply for removal through communications with MOFCOM. According to Article 30 of the Regulations, if these companies cooperate with MOFCOM's investigation, provide truthful statements about relevant facts, cease any illegal activities, take proactive measures to eliminate harmful consequences, and make and fulfill commitments as required, ensuring they no longer pose threats to China's national security and interests, they may apply to MOFCOM for removal from the control list. MOFCOM may decide to remove them from the control list based on the actual circumstances.
This round of sanctions occurred shortly after the US Congress passed the "National Defense Authorization Act of 2025 Fiscal Year," which was signed by President Biden and viewed by China as containing multiple "negative provisions related to China". China’s Ministry of Foreign Affairs and the Foreign Affairs Committee of the National People's Congress both expressed "strong dissatisfaction and firm opposition" to the act, accusing it of continuing to hype the "China threat," "advocate military support for Taiwan, suppress China's technological and economic development, restrict Sino-U.S. economic and trade exchanges as well as people-to-people interactions, blatantly interfere in China's internal affairs, and undermine China's sovereignty, security, and development interests." Both vows that "China will take necessary measures in accordance with the law to resolutely safeguard its national sovereignty, security, and development interests."
Direct involvement of these listed companies in military or defense activities in mainland China is highly unlikely. However, some may have had partnerships or supply chain connections in civilian sectors, such as electronic technologies or commercial aircraft components and systems integration. For example, Boeing has cooperated with China's civil aviation market in its commercial aircraft segment, though the listed entity pertains specifically to its defense and security division.
Certain small and medium-sized technology or equipment suppliers, such as Clear Align and Inter-Coastal Electronics, which provide subsystems or supporting services to major defense firms, might have engaged in electronic component procurement or R&D collaborations with China. Nonetheless, defense-related exports are typically subject to strict controls.
On the same day, 10 of the above 28 listed companies were also added to the unreliable entities by MOFCOM. For the unreliable entities regime, please refer to my former piece here.
The Ministry of Commerce Adds 28 U.S. Entities to the Export Control List
The Ministry of Commerce issued Announcement No. 1 of 2025 on January 2, stating that 28 U.S. entities have been added to the export control list.
According to the announcement, based on relevant provisions of the Export Control Law of the People's Republic of China and the Regulations on Export Control of Dual-Use Items of the People's Republic of China, and in order to safeguard national security and interests while fulfilling international obligations such as non-proliferation, the decision has been made to include 28 U.S. entities, including General Dynamics, on the export control list.
The announcement specifies the following measures:
The export of dual-use items to the aforementioned 28 U.S. entities is prohibited, and any ongoing related export activities must be immediately halted.
In exceptional cases where export is deemed necessary, exporters must submit an application to the Ministry of Commerce.
The announcement takes effect upon its publication.
Export Control List
(January 2, 2025)1. 通用动力公司（General Dynamics）
2. L3哈里斯公司（L3 Harris Technologies）
3. 英特磊公司（Intelligent Epitaxy Technology）
4. 可利尔阿莱恩公司（Clear Align LLC）
5. 波音防务、空间与安全集团（Boeing Defense, Space & Security）
6. 洛克希德·马丁公司（Lockheed Martin Corporation）
7. 雷神导弹与防务公司（Raytheon Missiles & Defense）
8. 洛克希德·马丁导弹与火控公司（Lockheed Martin Missiles and Fire Control）
9. 洛克希德·马丁航空公司（Lockheed Martin Aeronautics）
10. 标枪合资公司（Raytheon/Lockheed Martin Javelin Joint Venture）
11. 雷神导弹系统公司（Raytheon Missile Systems）
12. 通用动力军械与战术系统公司（General Dynamics Ordnance and Tactical Systems）
13. 通用动力信息技术公司（General Dynamics Information Technology）
14. 通用动力任务系统公司（General Dynamics Mission Systems）
15. 海岸间电子公司（Inter-Coastal Electronics）
16. 系统研究与模拟公司（System Studies & Simulation）
17. 铁山解决方案公司（IronMountain Solutions）
18. 应用技术集团（Applied Technologies Group）
19. 阿克西恩特公司（Axient）
20. 洛克希德·马丁导弹系统集成实验室（Lockheed Martin Missile System Integration Lab）
21. 洛克希德·马丁先进技术实验室（Lockheed Martin Advanced Technology Laboratories）
22. 洛克希德·马丁风险投资公司（Lockheed Martin Ventures）
23. 安杜里尔公司（Anduril Industries）
24. 海上战术系统公司（Maritime Tactical Systems）
25. 环太平洋防务公司（Pacific Rim Defense）
26. AEVEX航天公司（AEVEX Aerospace）
27. LKD航天公司（LKD Aerospace）
28. 顶峰科技公司（Summit Technologies Inc.）
Unreliable Entity List Working Mechanism
Announcement
2025 No. 1To safeguard national sovereignty, security, and development interests, and in accordance with the relevant laws such as the Foreign Trade Law of the People’s Republic of China, the National Security Law of the People’s Republic of China, and the Anti-Foreign Sanctions Law of the People’s Republic of China, the Unreliable Entity List Working Mechanism, pursuant to Articles 2, 8, and 10 of the Provisions on the Unreliable Entity List, has decided to include the following entities involved in arms sales to the Taiwan region on the Unreliable Entity List and take the following measures:
Entities Listed:
洛克希德·马丁导弹与火控公司 (Lockheed Martin Missiles and Fire Control)
洛克希德·马丁航空公司 (Lockheed Martin Aeronautics)
洛克希德·马丁导弹系统集成实验室 (Lockheed Martin Missile System Integration Lab)
洛克希德·马丁先进技术实验室 (Lockheed Martin Advanced Technology Laboratories)
洛克希德·马丁风险投资公司 (Lockheed Martin Ventures)
标枪合资公司 (Raytheon/Lockheed Martin Javelin Joint Venture)
雷神导弹系统公司 (Raytheon Missile Systems)
通用动力军械与战术系统公司 (General Dynamics Ordnance and Tactical Systems)
通用动力信息技术公司 (General Dynamics Information Technology)
通用动力任务系统公司 (General Dynamics Mission Systems)
Measures Imposed:
Prohibition on the above entities engaging in import and export activities related to China.
Prohibition on new investments by the above entities within China.
Denial of entry for senior executives of the above entities into China.
Revocation and non-approval of work permits, stay, or residence qualifications for senior executives of the above entities within China.
Matters not covered in this announcement shall be handled in accordance with the Provisions on the Unreliable Entity List.
This announcement shall take effect on the date of its publication.
Unreliable Entity List Working Mechanism
(Seal of the Ministry of Commerce)January 2, 2025