On June 8, 2026, the US Department of Defense/War (the Department or the Pentagon) released an updated version of its list of “Chinese Military Companies” operating in the United States, pursuant to the requirements of Section 1260H of the National Defense Authorization Act (NDAA) for Fiscal Year 2021 (the 1260H List). Compared to the previous version of the list (published in January 2025), the updated list adds 65 entities in total, including 17 new parent-level listings and 48 new subsidiaries of previously listed parent companies. The Department also removed 10 previously listed entities upon determining that they do not operate directly or indirectly in the United States.

The additions reach further across China’s economy than prior iterations of the 1260H List, capturing major Chinese technology companies (Alibaba, Baidu), electric vehicle and battery manufacturers (BYD, CALB, EVE Energy, NIO), solar manufacturers (JA Solar, Trina Solar), display and optical-component manufacturers (BOE, Tianma, Innolight), and drone and robotics companies (Autel Technology, Unitree, Robosense). 

Notably, the addition of biotechnology companies WuXi AppTec, Complete Genomics and Novogene implicates the ongoing implementation of the so-called Biosecure provisions of the NDAA for FY 2026, which restrict the use of US federal contract, grant, and loan funds to procure biotechnology equipment or services produced or provided by “Biotechnology Companies of Concern”—a category defined in part by reference to the 1260H List. This means that once the Biosecure prohibitions become effective, WuXi AppTec (as a major contract development and manufacturing organization, or CDMO) is likely to be subject to the federal funding restrictions.

The June 8 update follows the Pentagon’s February 2026 publication and immediate (and unexplained) deletion of a substantially similar updated list. The principal substantive difference between the withdrawn February version and the June 8 list is that ChangXin Memory Technologies, Inc. (CXMT) and Yangtze Memory Technologies Co., Ltd. (YMTC)—two major Chinese memory-chip manufacturers—remain on the active list, whereas the February version appeared to have removed them.

This action follows by just a few weeks the summit in Beijing between US President Donald Trump and Chinese President Xi Jinping. The Chinese Ministry of Foreign Affairs immediately responded to it, indicating that the “1260H List is yet another example of the U.S. overstretching the concept of national security and formulating discriminatory lists to go after Chinese businesses. China will take necessary measures to defend the rights and interests of Chinese companies.” As of the date of this alert, however, the Chinese government has not publicly taken any specific retaliatory measures in response to the updated 1260H List, as it did last month in response to US sanctions against so-called teapot oil refineries. 

Several newly-designated companies have already indicated that they are considering litigation against the United States to challenge their designation. To date, the Department has been successful in defending its use of the 1260H authority under the Administrative Procedures Act, which courts review under a standard that is generally deferential to US federal agencies.

This client alert summarizes the principal additions and removals reflected in the June 8 update; explains the legal effect of a 1260H designation, including impending federal government procurement restrictions; and identifies related NDAA provisions, including the Biosecure provisions.

Background: The 1260H List

The 1260H List identifies entities that the Secretary of Defense has determined to be “Chinese Military Companies” that are “operating directly or indirectly in the United States.” The term “Chinese Military Company” is broadly defined to include any entity that is identified by the Secretary of Defense and is directly or indirectly owned by, controlled by, beneficially owned by, affiliated with or acting (in an official or unofficial capacity) as an agent or on behalf of specified Chinese military, security or certain other government bodies, or that has been identified as a “military-civil fusion” contributor to the Chinese defense industrial base, and that is engaged in providing commercial services, manufacturing, producing or exporting.

The 1260H List initially served only as a “name and shame” tool, prompting US companies to consider whether to cut ties with listed entities, even where commercial relationships with those entities remained legal. In this respect, the principal effect of designation was initially reputational rather than legal. But through subsequent legislation, the 1260H List has increasingly become a trigger for substantive restrictions affecting transactions involving designated entities. These restrictions include Pentagon procurement restrictions targeting 1260H entities, a secondary ban on Pentagon contracts with companies that engage lobbyists for 1260H-designated entities, and the use of federal funds for biotechnology equipment and services from 1260H entities. 

What’s New on the June 8 List?

New Parent-Level Designations

The Department added the following 17 entities as stand-alone listings:

• Alibaba Group Holding Limited (Alibaba)
• Autel Intelligent Technology Corp., Ltd. (Autel Technology)
• Baidu, Inc.
• BOE Technology Group Company Limited (BOE)
• BYD Company Limited (BYD)
• CALB Group Co., Ltd. (CALB)
• EVE Energy Co., Ltd.
• Hangzhou Yushu Technology Co., Ltd. (Unitree)
• JA Solar Technology Co., Ltd.
• NIO, Inc.
• Novogene Company Limited
• Robosense Technology Co., Ltd.
• Tianma Microelectronics Co., Ltd.
• TP-Link Technologies Co., Ltd.
• Trina Solar Co., Ltd.
• WuXi AppTec Co., Ltd.
• Zhongji Innolight Co., Ltd. (Innolight)

New Subsidiaries

The Department also expanded the subsidiary coverage of 15 previously listed parent companies, adding the following 48 entities:

• Aviation Industry Corporation of China (AVIC): Align Aerospace LLC; Avicopter PLC; Cirrus Design Corporation; and Continental Aerospace Technologies, Inc.
• BGI Group: BGI Americas Corporation; Complete Genomics, Inc.; GBI Diagnostics, Inc.; Innomics Inc.; and STOmics Americas Ltd.
• China Communications Construction Group (CCCG): CCCC Design and Consulting Group Co., Ltd.; CCCC First Harbor Engineering Bureau Co., Ltd.; CCCC Second Navigation Engineering Bureau Co., Ltd.; CCCC Third Navigation Engineering Bureau Co., Ltd.; China Transportation Materials Co., Ltd.; Shanghai Zhenhua Shipping Co., Ltd.; and ZPMC North America, Inc.
• China COSCO SHIPPING: China Ocean Shipping Company Ltd.; COSCO SHIPPING Logistics Supply Chain Co., Ltd.; and Shanghai Ship and Shipping Research.
• China Electronics Corporation (CEC): China Information Security Research Institute; IRICO Group Company, Ltd.; Shenzhen CEC Blue Ocean Holdings Co., Ltd.; and The 6th Research Institute of CEC.
• China Electronics Technology Group Corporation (CETC): 14th Research Institute of CETC; 15th Research Institute of CETC; and CETC Research Institute 32.
• China Mobile Communications Group: Aspire Technologies (Shenzhen) Limited and China Mobile Hong Kong (BVI) Limited.
• China National Offshore Oil Corporation (CNOOC): China BlueChemical Limited.
• China North Industries Group (Norinco): China North Chemical Research Academy Group Co., Ltd.; Chinese Academy of Ordnance Science; Kiekert USA Inc.; Merit Automotive Electronics Systems S.L.U.; North Petroleum International Company Limited; and Yunnan Yuanjin Optical Instrument Co., Ltd.
• China South Industries Group (CSGC): Baoding Tianwei Baobian Electric Co., Ltd.; Beijing Beiji Mechanical and Electrical Industry Co., Ltd.; Changan US R&D Center, Inc.; China South Industries Group Corporation No. 59 Research Institute Co., Ltd.; and Sichuan Jian’an Industry Co., Ltd.
• China SpaceSat: Aerospace Star Space Technology Application Co., Ltd.
• China Telecom Group: China Telecom Satellite Communications Co., Ltd.; New Guomai Digital Culture Co., Ltd.; Tianyi Cloud Technology Co., Ltd.; and Zhongjie Communications Co., Ltd.
• China Unicom: Beijing Telecom Planning and Designing Institute Company Limited.
• COMAC: Shanghai Aircraft Design and Research Institute.
• SDIC Intelligence: Beijing Meiya Hongshu Technology Co., Ltd.

Removals (as they were determined to not operate directly or indirectly in the United States) 

• Anhui Sun Create Electronics Co., Ltd. 
• China International Information Services Ltd.
• China National Chemical Engineering Co., Ltd. 
• China Traffic Construction USA, Inc.
• CNOOC China Limited (CNOOC China Ltd.)
• CNOOC International Trading Co., Ltd. (CNOOC International Trading) 
• COSCO SHIPPING Finance Co., Ltd.
• Costar Group Co., Ltd. (Costar) 
• GLARUN Technology Co., Ltd.
• Taiji Computer Co., Ltd.

What Does It Mean?

As noted above, several procurement restrictions tied directly to the 1260H List are scheduled to come into effect this year and next, which will be important for companies to consider, especially if they are US government contractors.

Section 805 of the FY 2024 NDAA prohibits the Pentagon from “enter[ing] into, renew[ing], or extend[ing]” certain contracts involving entities identified on the 1260H List or entities “subject to [their] control.” This prohibition has two components, taking effect on a staggered schedule:

• Entity Ban: Effective June 30, 2026, the Pentagon is prohibited from entering into, renewing or extending a contract for the procurement of goods, services or technology with an entity on the 1260H List or with an entity subject to their control.
• Product Ban: Effective June 30, 2027, the Pentagon is prohibited from entering into, renewing or extending a contract for the procurement of goods or services that “include goods or services produced or developed by” a 1260H entity or an entity subject to the control of a 1260H entity. However, this product-based prohibition does not prohibit acquisitions of end items or components that contain components (or subcomponents) from 1260H entities. 

In addition to Section 805, several other recent NDAA provisions impose restrictions that are triggered by, or tied to, a 1260H designation, including restrictions on the procurement of additive manufacturing machines, AI applications or contracts with a company if it is (or its parents or subsidiaries are) party to a contract with an entity that engages in “lobbying activities” for Section 1260H companies. This provision effectively creates a de facto blacklist of lobbyists based on the lobbyists’ work for such entities.

Separately, Section 8531 of the NDAA for FY 2026 (part of the so-called COINS Act, which codified restrictions on US outbound investment to China) requires the President, within two years, to submit a report to Congress assessing whether any Chinese entity on the 1260H List qualifies for inclusion on Treasury’s Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List. Inclusion of a company on that list would prohibit US persons from purchasing or selling the publicly traded securities of that company. If such an NS-CMIC designation were to occur, it could prove particularly consequential for newly added 1260H entities whose securities are traded in the United States—e.g., Alibaba, Baidu and NIO—as an NS-CMIC designation would extend the practical effect of a 1260H listing beyond federal procurement, potentially into the US capital markets.

The Biosecure provisions of the NDAA for FY 2026 will (after a lengthy implementation period) prohibit federal government contract, grant and loan funds from being used to acquire biotechnology equipment or services produced or provided by certain “biotechnology companies of concern” (BCC) or to use such equipment and services in the performance of federally funded contracts. BCCs will be defined by reference to a list to be developed by the Office of Management and Budget (OMB), which will include (but not necessarily be limited to) companies on the 1260H List, at least to the extent that the company is “involved in the manufacturing, distribution, provision, or procurement of any biotechnology equipment or service.” WuXi AppTec has long been a potential target for inclusion on the 1260H List, including as a result of bipartisan calls for such action by the leadership of the Select Committee on China dating back several years.

The Biosecure restrictions will be implemented through revisions to the Federal Acquisition Regulations (FAR) for contracts and in financial assistance regulations for grants, cooperative agreements and loans. The Biosecure provisions will, among other restrictions, prohibit acquisitions by federal agencies (such as the Department of Veterans Affairs) of biotechnology equipment or services produced or provided by the designated entities or where such equipment or services will be used in the performance of a federal contract. Given the roles of some Section 1260H-listed entities in pharmaceutical, biotechnology and medical device supply chains—particularly following recent expansions—companies should assess whether their reliance on such entities could affect their ability to engage in US federal procurement or receive federal grant, cooperative agreement or loan funds. 

In addition to US-related issues, companies should be vigilant for actions China may take in response. As we noted above, while Beijing has immediately criticized the expansion of the 1260H List, there have not been any specific or immediate retaliatory actions taken. However, while there may seem to be a temporary détente between the United States and China on escalatory trade issues, regulatory actions that may have significant effects for companies’ supply chains that touch both the United States and China remain ever present. 

WilmerHale regularly advises US and multinational companies on Section 1260H designation risk, related procurement restrictions and broader China-related compliance matters. Please contact the authors of this alert or any member of the WilmerHale team with whom you regularly work for further information.