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BIS exercised authority under EAR Part 744 (Control Policy: End-User and End-Use Based) to add CNOOC Ltd. to the Entity List (Supplement No. 4 to Part 744) with a presumption of denial licence review policy. The listing covers all EAR-subject items except:
1. Crude oil and refined petroleum products corresponding to 37 specific Harmonised System (HS) codes — ensuring energy supply continuity for third-country buyers. 2. Items required for joint-venture operations with Country Group A:1 (major allied) nations conducted outside the South China Sea.
No licence exceptions apply for otherwise-restricted transactions.
Beijing Skyrizon Aviation Industry Investment Co., Ltd. (alias Beijing Tianjiao Aviation Industry Investment Company) was added to the MEU List (Supplement No. 7 to Part 744), imposing a licence requirement under EAR §744.21 on exports of items subject to MEU controls.
Two Russian entities were simultaneously removed from the MEU List as administrative clean-up (duplicate entries already covered by Entity List listings):
The action represents the first time BIS placed a major Chinese state-owned energy company on the Entity List on purely geopolitical grounds (maritime coercion) rather than proliferation, technology-diversion, or forced-labour rationales. CNOOC operates the largest deep-water drilling programme in the South China Sea, including contested areas claimed by Vietnam, the Philippines, Malaysia, and Brunei.
CNOOC Ltd. (the Hong Kong-listed offshore subsidiary of state-owned CNOOC Group) was simultaneously designated by the Department of Defense as a Communist Chinese Military Company (CCMC) under Section 1237 of the FY1999 National Defense Authorization Act — triggering separate investment restrictions on U.S. persons trading its ADRs. The BIS Entity List action and the DoD CCMC designation were concurrent but operationally distinct (export-control licence requirement vs. securities-trading prohibition).
NYSE announced the delisting of CNOOC Ltd.'s ADRs shortly after the dual designation. CNOOC subsequently challenged the CCMC designation; a U.S. district court did not issue a preliminary injunction blocking the Entity List aspect, which remained in force. CNOOC was later removed from the CCMC list under the Biden administration but the Entity List entry continued under review.
Beijing Skyrizon Aviation Industry Investment Co., Ltd. is an aviation-sector holding company with interests in turbine-engine manufacturing and related aerospace components. The MEU designation reflects the End-User Review Committee's (ERC) finding that Skyrizon qualifies as a "military end user" under EAR §744.21, i.e., it supports the People's Liberation Army's aviation procurement and modernisation programmes.
offshore drilling operations in the South China Sea, including subsea production systems, blowout preventers, and drilling automation equipment.
but any U.S.-origin equipment supply to contested-area operations triggers a licence requirement with presumption of denial.
major U.S. passive index funds that prohibit CCMC holdings.
components or sub-systems transiting its supply chain.
List entry (distinct from the CCMC removal that occurred under Biden).
changes in commodity classification or Skyrizon's downstream equipment procurement.