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China Adds 28 U.S. Entities to Export Control List and Announces Unreliable Entity Measures

On January 2, 2025, China's Ministry of Commerce announced a significant move under its export control framework, adding 28 U.S. entities to the export control list. This decision, guided by the Export Control Law of the People's Republic of China and related regulations, is aimed at protecting national security and fulfilling non-proliferation commitments. The Ministry specified that these entities would be restricted from receiving exports of dual-use items, with all ongoing related export activities required to cease immediately. Should there be any exceptional cases necessitating exports, businesses must seek approval from the Ministry of Commerce.

The entities added to the list include major U.S. defense and aerospace companies such as General Dynamics, Lockheed Martin, Raytheon, and Boeing, among others. Below is a full list of the entities affected by the new export controls:

  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. IronMountain 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.

Suzhou Vega Technology Co., LTD.

In addition to this list, the Ministry also published an announcement regarding the Unreliable Entity List, targeting Lockheed Martin Missiles and Fire Control, Lockheed Martin Aeronautics, and eight other companies. Measures include bans on imports and exports involving China, restrictions on new investments within the country, and denial of work permits or residence for senior management personnel. The companies affected by these measures are:

● 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

The announced measures aim to safeguard China's national interests and limit the impact of entities that are deemed to pose risks to security and stability. These steps come as part of China's broader strategy to regulate the activities of foreign entities operating in the country.

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