China: U.S. Designations as Unreliable Entities + Watchlist
- Arne Mielken
- Jan 24, 2025
- 3 min read

China’s Ministry of Commerce (MOFCOM) announced two significant measures targeting U.S. companies, escalating tensions in the ongoing U.S.-China economic and technological competition.
These announcements include:
Ten U.S. companies, including Lockheed Martin, Raytheon Missile Systems, and General Dynamics, were added to the Unreliable Entity List for their involvement in arms sales to Taiwan.
Restrictions include:
○ A ban on all import and export activities involving China.
○ A prohibition on new investments in China.
○ Entry restrictions for senior executives.
From the Press Release:
“Working Mechanism of the Unreliable Entity List
Announcement No. 1, 2025
In order to safeguard national sovereignty, security, and development interests, and in accordance with the Foreign Trade Law of the People's Republic of China, the National Security Law of the People's Republic of China, the Anti-Foreign Sanctions Law of the People's Republic of China, and other relevant laws, the Unreliable Entity List Working Mechanism has decided, in accordance with Articles 2, 8, and 10 of the Regulations on the Unreliable Entity List, to include the following entities on the Unreliable Entity List:
● Lockheed Martin Missiles and Fire Control
● Lockheed Martin Aeronautics
● Lockheed Martin Missile System Integration Lab
● Lockheed Martin Advanced Technology Laboratories
● Lockheed Martin Ventures
● Raytheon/Lockheed Martin Javelin Joint Venture
● Raytheon Missile Systems
● General Dynamics Ordnance and Tactical Systems
● General Dynamics Information Technology
● General Dynamics Mission Systems
These companies are involved in arms sales to Taiwan.
The following measures have been taken:
The above-mentioned enterprises are prohibited from engaging in import and export activities related to China;
The above-mentioned enterprises are prohibited from making new investments in China;
Entry of senior management personnel from the above-mentioned enterprises is prohibited;
Work permits, stay, or residence qualifications in China for the senior managers of the above-mentioned enterprises are not approved and will be canceled.
Matters not covered in this announcement shall be implemented in accordance with the Provisions on the Unreliable Entity List.
This announcement shall take effect from the date of publication”.
Twenty-eight U.S. entities, including Boeing Defense, L3Harris, and subsidiaries of Lockheed Martin, were placed on the Export Control Watchlist. These entities are prohibited from exporting dual-use items to China, with existing exports ordered to cease immediately unless granted special approval.
The statement:
Ministry of Commerce Announcement No. 1 of 2025
Issued by: Safety and Regulation Bureau Date: January 2, 2025
The Ministry of Commerce (MOFCOM) has announced the addition of 28 U.S. entities, including General Dynamics and Lockheed Martin, to China's export control list. This decision aligns with the Export Control Law of the People's Republic of China and the Regulations on Export Control of Dual-Use Items. The move aims to safeguard China's national security, fulfill international obligations, and support non-proliferation goals.
Key Measures:
The export of dual-use items to these 28 U.S. entities is now prohibited, and all related export activities must cease immediately.
In cases of necessity, export operators must apply for approval from the Ministry of Commerce.
The announcement takes effect immediately upon publication.
Export Control List (January 2, 2025):
General Dynamics
L3 Harris Technologies
Intelligent Epitaxy Technology
Clear Align LLC
Boeing Defense, Space & Security
Lockheed Martin Corporation
Raytheon Missiles & Defense
Lockheed Martin Missiles and Fire Control
Lockheed Martin Aeronautics
Raytheon/Lockheed Martin Javelin Joint Venture
Raytheon Missile Systems
General Dynamics Ordnance and Tactical Systems
General Dynamics Information Technology
General Dynamics Mission Systems
Inter-Coastal Electronics
System Studies & Simulation
Iron Mountain Solutions
Applied Technologies Group
Axient
Lockheed Martin Missile System Integration Lab
Lockheed Martin Advanced Technology Laboratories
Lockheed Martin Ventures
Anduril Industries
Maritime Tactical Systems
Pacific Rim Defense
AEVEX Aerospace
LKD Aerospace
Summit Technologies Inc.




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