Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

On June 8, 2026, the US Department of Defense published its annual update to the Section 1260H Chinese Military Companies (CMIC) list, adding 65 entities (17 new parent companies and 48 subsidiaries), bringing the total to approximately 188–200 designated entities. Major additions span EV and battery manufacturing (BYD, NIO, CATL), consumer internet (Alibaba, Baidu, Tencent), semiconductors (SMIC, YMTC, CXMT), solar (JA Solar, Trina Solar), biotech (BGI Genomics, WuXi AppTec), drones/robotics (DJI, Unitree, RoboSense), and telecoms (TP-Link). Effective June 30, 2026, DoD is prohibited from procuring goods, services, or technology directly from listed entities; effective June 30, 2027, the ban extends to indirect supply-chain procurement through prime contractors and all sub-tiers.

The Federal Acquisition Regulatory Council (DOD, GSA, and NASA) published a Notice of Proposed Rulemaking on 17 February 2026 (FR Doc 2026-03065, 91 FR 7223) implementing Section 5949(a) of the NDAA FY2023 (Pub. L. 117-263), which bars executive agencies from acquiring electronic products or services containing semiconductor components designed, produced, or provided by SMIC, CXMT, YMTC, or their affiliates. A Part B prohibition extends the restriction to "critical systems" whose subsystems incorporate covered semiconductors regardless of COTS sourcing. The comment period closed 20 April 2026; proposed prohibitions take effect 23 December 2027.

The Bureau of Industry and Security (BIS) issued an Interim Final Rule amending the Export Administration Regulations (EAR) to automatically extend Entity List, Military End-User List, and certain other restricted- party controls to any unlisted entity that is at least 50% owned — individually or in the aggregate — by one or more listed parties. The threshold is set to mirror the long-standing OFAC 50% rule. Published 90 FR 47201 (Sept. 30, 2025); effective Sept. 29, 2025. A Temporary General License covering pre-existing transactions with 50%-owned affiliates expired on Nov. 28, 2025. The rule was subsequently suspended for one year by BIS on Nov. 10, 2025 (FR Doc. 2025-19846) as part of the post-Busan US-China understanding.

On 6 September 2024 the Dutch government announced an expansion of its national export-control measure on advanced semiconductor manufacturing equipment, bringing two additional ASML DUV immersion lithography systems — TWINSCAN NXT:1970i and NXT:1980i — under a Dutch national authorisation requirement for shipments to destinations outside the EU. The measure took effect on 7 September 2024 via a ministerial regulation published in Staatscourant 2024 no. 29008. Until this point those two older system variants were controlled extraterritorially through the US Foreign Direct Product Rule; the change transfers licensing authority from BIS to the Dutch government and aligns the Dutch national list more tightly with the perimeter set by the June-2023 measure on NXT:2000i+. ASML characterised the update as a "technical change" with no expected impact on its 2024 financials or longer-term outlook.

China registered the National Integrated Circuit Industry Investment Fund III Co., Ltd. ("Big Fund III") in Beijing on 24 May 2024 with RMB 344 billion (~USD 47.5 billion) of registered capital — the largest single capital raise of the three Big Fund phases (Phase I 2014: RMB 138.7bn; Phase II 2019: RMB 204bn). Nineteen state-owned investors contribute, led by the Ministry of Finance (17% / RMB 60bn) and the six largest state-owned commercial banks (ICBC, ABC, BoC, CCB ~6.25% each at RMB 21.5bn; BoCom RMB 20bn; PSBC RMB 8bn). Duration 15 years (24 May 2024 → 23 May 2039). The fund explicitly targets the chokepoints exposed by US BIS October 2022/2023/2024 controls — semiconductor manufacturing equipment, advanced memory (HBM/DRAM), AI accelerators, and third-generation compound semiconductors (SiC, GaN).