Effective Jan. 2, China’s Ministry of Commerce has added add 28 U.S. entities to its new dual-use export control list. This is the first batch of entities placed on this list, which was introduced by China’s dual-use export control regulations in late 2024.
As a result of this action, exports of dual-use items to the listed entities are prohibited and all relevant export activities currently being carried out must be halted immediately. If such exports are necessary under special circumstances the exporter must apply for a dual-use export license from MOFCOM. In addition, most of the 28 entities are also on the sanctions list maintained by China’s Ministry of Foreign Affairs, and it is expected that both sets of restrictions will be applied to these entities concurrently.
China has also added 10 U.S. companies to its unreliable entity list, which was first introduced in 2020. Entities on this list are prohibited from engaging in import and export activities related to China as well as making new investments in China. In addition, management of these entities are prohibited from entering China; new visa applications will not be approved and existing visas will be canceled.
China is expected to impose additional control measures on U.S. companies and end-users. U.S. companies’ subsidiaries in China should closely monitor whether they have business relationships with entities on China’s lists, assess risks, and develop mitigation plans immediately. They should also develop and implement a China export control process to manage increasing export control matters in China.
For more information on these developments, or assistance taking the recommended actions, please contact Xiaofeng Xu via email.
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