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China: U.S. Designations as Unreliable Entities + Watchlist


Four men in suits at a conference table with a large Chinese flag. Cityscape visible through a large window, creating a formal setting.
Chinese officials discussing export control measures against U.S. companies in a high-rise office setting.

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:

  1. The above-mentioned enterprises are prohibited from engaging in import and export activities related to China;

  2. The above-mentioned enterprises are prohibited from making new investments in China;

  3. Entry of senior management personnel from the above-mentioned enterprises is prohibited;

  4. 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:

  1. The export of dual-use items to these 28 U.S. entities is now prohibited, and all related export activities must cease immediately.

  2. 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):

  1. General Dynamics

  2. L3 Harris Technologies

  3. Intelligent Epitaxy Technology

  4. Clear Align LLC

  5. Boeing Defense, Space & Security

  6. Lockheed Martin Corporation

  7. Raytheon Missiles & Defense

  8. Lockheed Martin Missiles and Fire Control

  9. Lockheed Martin Aeronautics

  10. Raytheon/Lockheed Martin Javelin Joint Venture

  11. Raytheon Missile Systems

  12. General Dynamics Ordnance and Tactical Systems

  13. General Dynamics Information Technology

  14. General Dynamics Mission Systems

  15. Inter-Coastal Electronics

  16. System Studies & Simulation

  17. Iron Mountain Solutions

  18. Applied Technologies Group

  19. Axient

  20. Lockheed Martin Missile System Integration Lab

  21. Lockheed Martin Advanced Technology Laboratories

  22. Lockheed Martin Ventures

  23. Anduril Industries

  24. Maritime Tactical Systems

  25. Pacific Rim Defense

  26. AEVEX Aerospace

  27. LKD Aerospace

  28. Summit Technologies Inc.

 

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