On June 8, 2026, the Department of War released its updated 1260H List on ‘Chinese Military Companies’ operating directly or indirectly in the US. The latest iteration demonstrates an escalatory approach to numbers of Chinese firms and subsidiaries targeted. In 2025, this number was 134. In 2026, the net new addition is of 54 firms, after accounting for the delisting of 10 firms, including subsidiaries of COSCO Shipping and China Electronics Corporation (CEC). Curiously, before this announcement, a February 2026 release listing 154 firms was withdrawn from the Federal Register without an official explanation.
This update expands on the breadth of entities that make China’s Military-Civil Fusion (MCF) processes possible, and enable its military-industrial complex, arguably legitimately. First-time additions include state-empowered internet giants such as Alibaba and Baidu, EV big-shots BYD and NIO, one of the world’s largest robotics firms – Unitree, biotech major WuXi AppTec, networking vendor TP-Link, LiDAR suppliers Hesai and RoboSense, display manufacturer BOE, battery firms CALB and EVE Energy, and solar producers JA Solar and Trina Solar. The DoW has described both Alibaba and Baidu as “MCF-backed” contributors to the Chinese “defence industrial base” – an articulation that furthers competition with and contention to Beijing’s defence industrial institutionalisation (especially through a nexus between the party-state and major SOEs, POEs, and OEMs), exports, and lock-in arrangements with developing economies.
While the entity designations on 1260H do not amount to “sanction,” the legal consequences for listed firms are drastic due to the supporting legislative architecture in the US. Per Section 805 of the 2024 National Defence Authorisation Act (NDAA), the DoW is prohibited from entering new contracts with listed entities or their subsidiaries from June 30, 2026, with a broader prohibition on the procurement of goods or services from these entities taking effect from June 30, 2027. Adding to this is Section 1346 of the 2025 NDAA, which furthers the targets to any parent or subsidiary entity with ≥50% equity control. This is because major conglomerates like AVIC often have over a 100 subsidiaries, or non-military-affiliated companies may be owned by diversely profiled, military-affiliated parent organisations.
Both the Chinese foreign ministry, as well as firms like Alibaba, Baidu, and BYD, have come out rejecting the designations as baseless and discriminatory, and have signalled willingness to pursue counteractions and legal remedies.
As with the US Bureau of Industry Security’s policy of “small yard, high fences” materialises, 1260H will continue to act as a risk advisory for a host of American universities, businesses and civil society groups, furthering the divide between Washington and Beijing’s technological ecosystems. With every annual edition, the net is cast wider, and China may find its prolonged and infamous dual-use operations and MCF-enabled militarisation harder to pursue, especially where global integration reaps benefits.
These entity designations also serve as sort of a response to China’s own legislative enactments. In particular, Regulations No. 834 and 835 of April 2026, which together create a comprehensive layer for Chinese firms exposed to such designations, are both a symptom and a trigger of such back-and-forth. In that sense, the vicious cycle of US-China strategic competition continues, and the ever-expanding 1260H is one of its most visible consequences.