Update to U.S.-China Trade Relations: China Adds U.S. Companies to New Restricted List

Defense Technology Companies Targeted by Latest Chinese Trade Ruling

Effective January 2, 2025, the China Ministry of Commerce named 28 U.S. companies to its new dual-use export control list. The list, introduced just last month on December 3, 2024, is described in a recent Phillips Lytle client alert, among other China-related trade matters. (See previous alert from January 3, 2025). As a result of this action, exports from China to the listed U.S. entities are prohibited, absent a special license from the Ministry.

The companies listed below largely consist of U.S. defense technology suppliers and integrators — with those related to Raytheon, Lockheed Martin and General Dynamics leading the list.

Ten of the companies were also added to China’s “Unreliable Entities List,” which was created in 2020. Companies on that list are immediately banned from engaging in import/export activities in connection with China, as well as from making any new investments in China or Chinese entities. Additionally, executives and management personnel of these companies are personally prohibited from entering China; existing visas are canceled, and new ones will not be approved.

The recent trade events and regulations noted in our January 3, 2025 alert suggest that further restrictive control measures on commerce with U.S. companies and end-users may be expected.

Trade counsel should contact clients having subsidiaries or affiliates in China to determine whether they have existing business relationships with companies on these lists, or whether their supply chains involve China-sourced products or services from any of them, and assess possible risks from such activity — especially if the subsidiary or affiliate itself exports from China. It may be prudent to consider developing and implementing China export control compliance measures to manage potential exposure from such relationships.

Added to New Export Control List

• AEVEX Aerospace
• Anduril Industries
• Applied Technologies Group
• Axient
• Boeing Defense, Space & Security
• Clear Align LLC
• General Dynamics
• General Dynamics Information Technology
• General Dynamics Mission Systems
• General Dynamics Ordnance and Tactical Systems
• Intelligent Epitaxy Technology
• IronMountain Solutions
• Inter-Coastal Electronics
• L3Harris
• LKD Aerospace
• Lockheed Martin Aeronautics
• Lockheed Martin Advanced Technology Laboratories
• Lockheed Martin Corporation
• Lockheed Martin Missiles and Fire Control
• Lockheed Martin Missile System Integration Lab
• Lockheed Martin Ventures
• Maritime Tactical Systems
• Pacific Rim Defense
• Raytheon Missile Systems
• Raytheon Missiles & Defense
• Raytheon/Lockheed Martin Javelin Joint Venture
• Summit Technologies, Inc.
• System Studies & Simulation

Added to Unreliable Entities List

• General Dynamics Information Technology
• General Dynamics Mission Systems
• General Dynamics Ordnance and Tactical Systems
• Lockheed Martin Advanced Technology Laboratories
• Lockheed Martin Aeronautics
• Lockheed Martin Missiles and Fire Control
• Lockheed Martin Missile System Integration Lab
• Lockheed Martin Ventures
• Raytheon/Lockheed Martin Javelin Joint Venture
• Raytheon Missile Systems