决斗清单：中国对1260H条款扩张的回应和模式中的风险——美国利益相关者应该知道什么

June 2026 Executive summary Washington and Beijing are increasingly reaching for the same instrument: targeted, list-based tools, including procurement bans, export-control designations, sanctions listings andinvestment restrictions, that let each pressure the other without forcing a broader rupture in the In practice, the measure changes little, because most of the46 were already restricted. Lockheed Martin and Raytheonhave sat on the Unreliable Entity List since 2023, and Chinaadded General Dynamics, several Boeing Defense units andothers across 2024 and 2025. The newer autonomy firms nownamed, among them Anduril, Shield AI and Edge Autonomy,were placed on that list in 2025. Most of the 46, in other words,had already been swept into China’s earlier countermeasuresover US arms sales to Taiwan, whether through the Unreliable On June 22, 2026, the People’s Republic of Chinaannounced two new restrictive measures affecting dozensof US companies. The move came two weeks after the USDepartment of Defense, on June 8, expanded its Section1260H list of “Chinese Military Companies” (CMCs) by65 entities, among them several of China’s best-known These actions look limited in their immediate commercialimpact, but they are a signal of expanding regulatory risk forUS companies in advanced technology, critical supply chainsand strategic industrial sectors. The restrictions stop well The Export Control Entity List: The The MOFCOM listing is the one to read closely, and not onlyfor who is on it. Its immediate legal effect is narrower than ageneral rare-earth embargo, because the measure is entityspecific. It does not halt China’s rare-earth exports as awhole, and it leaves China’s other US customers untouched.What it does is effectively cut the named firms off from China- What China announced China moved on two fronts on June 22. The Ministry ofFinance (MOF) barred government procurement entities frombuying goods or services from 46 US companies in coveredprojects. The Ministry of Commerce (MOFCOM) separatelyadded 10 US companies to the Export Control Entity List, The rule also appears intended to reach beyond China’sborders. MOFCOM’s announcement prohibits organizationsand individuals in any country or region from transferring orsupplying China-origin dual-use items to the listed firms, so onits face the measure is aimed at offshore transfers of China-origin items and not only at goods shipped from China. The The procurement ban: Largely symbolic The 46 companies are mostly US defense contractors, amongthem Lockheed Martin, Raytheon, Boeing Defense, Space& Security, General Dynamics Land Systems and GeneralAtomics, together with newer drone manufacturers such as The profile of the 10 firms is what gives the measure its weight. China’s restrictive lists have historically centered on conventionaldefense suppliers. This round concentrates instead on two areas central to the current contest: rare earths and unmannedsystems. It names the two companies at the heart of the American effort to rebuild a domestic rare-earth and permanent- Alongside them is a cluster of drone and autonomy companies: Aveox, Red Cat Holdings and its Teal Drones subsidiary, JaiaRobotics (autonomous underwater vehicles) and IMSAR (synthetic-aperture radar). The remainder are established defense and The choice of targets carries a message beyond the individual companies. Beijing went after US firms that depend on Chineseinputs, and it did so in the sectors where China, not the US, holds the supply-chain leverage. That let it aim squarely at US industrial-policy priorities, and at firms tied to US military modernization, while leaving the cost to its own exporters close to nil. The actioncarries a real compliance dimension, but it is at least as much a strategic signal: China will use its own export-control machinery to China’s restrictive-list toolkit That architecture has matured considerably over the past two years, and in structure it now resembles the US restricted-partymodel. The four lists below are Beijing’s principal instruments; the Export Control Entity List used here is only one of them.Clients should monitor all four, for their own names and for those of key counterparties, with particular attention to critical A structural difference: China’s system is more list-based than the EAR US companies tend to read China’s export-control regime through the lens of the US Export Administration Regulations(EAR), and the comparison misleads. As a general matter, China’s dual-use system is more list-based than the EAR. Unlike theEAR, it does not contain a broad EAR99-style residual category that pulls nearly all commercial items into the export-control The practical point for exposure analysis follows from this. Appearing on China’s Export Control Entity List does not sever acompany from all Chinese-origin goods, and the right question is not whether an input comes from China, but whether the The more Washington relies on list-based n