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Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
The BIOSECURE Act of 2025 creates a two-track federal procurement bar:
Track 1 — §1260H entities (BGI, MGI): Once OMB publishes the BCC list and the FAR is revised, agencies and contractors have 60 days before prohibitions take effect. BGI Genomics and its US subsidiary MGI Tech are already on the DoD §1260H Chinese-military-company list, making them the immediate targets. WuXi AppTec and WuXi Biologics — prominent in earlier draft versions — are not on the 1260H list and therefore require a separate OMB designation.
Track 2 — Additional OMB-designated BCCs: OMB must publish an initial BCC designation list within 1 year of enactment (by December 2026), then issue implementing guidance within 180 days after the list. The FAR Council must then revise procurement regulations within 1 year of that guidance. Prohibitions take effect 90 days after the FAR revision. Maximum timeline to full enforcement: approximately 970 days from signing (~Q3 2028).
Scope of prohibited "biotechnology equipment or services": The definition spans genetic sequencers and associated software/firmware as well as services for researching, analyzing, or detecting biological materials and transmitting associated data — broad enough to cover genomic-sequencing platforms, bioinformatics services, and contract research/development involving human genetic data.
Federal contractor pass-through: Agencies cannot enter into, extend, or renew contracts with any entity (not just direct biotech firms) that uses covered BCC equipment/services in performing work under federal contracts, grants, or loans. This creates a supply-chain due-diligence obligation for the broader life-sciences and CRO ecosystem.
Grandfather protection: Existing contracts entered before the FAR effective date receive a five-year grace period — meaning pre-existing contracts could remain valid until approximately 2033. This prevents immediate disruption for ongoing clinical-trial and R&D partnerships.
S.3469 was introduced in the 119th Congress by Senators Gary Peters (D-MI) and Bill Hagerty (R-TN), building on the bipartisan momentum from H.R.8333 (118th Congress), which the House passed 306–81 in September 2024 but which failed to advance in the Senate before adjournment. Senators Hagerty and Peters submitted a revised floor amendment (S.Amdt.3748) to the FY26 NDAA on July 31, 2025; it was adopted by voice vote on October 9, 2025, and survived conference with the House. President Trump signed the NDAA on December 18, 2025.
| Entity | §1260H status | Timeline |
|---|---|---|
| BGI Genomics / BGI Group | Listed | FAR + 60 days (~2028) |
| MGI Tech (BGI subsidiary) | Listed | FAR + 60 days (~2028) |
| Complete Genomics (BGI subsidiary) | Likely covered via BGI | FAR + 60 days (~2028) |
| WuXi AppTec | Not listed | OMB designation required; FAR + 90 days |
| WuXi Biologics | Not listed | OMB designation required; FAR + 90 days |
WuXi AppTec had ~63% of revenue from North American clients at peak; the revenue-cliff risk depends on whether OMB designates them and when. Their ongoing capacity-divestiture and US-entity restructuring efforts are partly anticipatory of this designation process.