On Wednesday, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) added seven Chinese space, aerospace, and related technology entities — including a publicly traded company — to its Entity List. U.S. companies involved in exports, reexports, or transfers with any of the seven organizations, like all entries on BIS’s Entity List, will now face license requirements.

The Seven Added Entities

There are currently nearly 600 China-based entities that appear on the Entity List. BIS stated that the seven added entities were acquiring and attempting to acquire U.S.-origin items in support of China’s military modernization efforts.

• Six of the seven added entities were identified as research institutes affiliated with the Chinese military.

• China Aerospace Science and Technology Corporation (CASC) 9th Academy 771 Research Institute

• China Aerospace Science and Technology Corporation (CASC) 9th Academy 772 Research Institute

• China Academy of Space Technology 502 Research Institute

• China Academy of Space Technology 513 Research Institute

• China Electronics Technology Group Corporation 43 Research Institute

• China Electronics Technology Group Corporation 58 Research Institute

• The seventh entity, Zhuhai Orbita Control Systems, is a satellite company based in southern China.

• The company is publicly traded on the Shenzhen Stock Exchange.

• According to a May securities disclosure, Zhuhai Orbita Aerospace Technology’s "satellite constellation and big data products mainly [are] satellite data, satellite software, and comprehensive satellite service products, with target customers including the military."

The BIS Entity List and Beyond

The Entity List identifies companies for which there is reasonable cause to believe are involved in or may become involved in activities contrary to the national security or foreign policy of the U.S.

• Entity List additions are determined by the interagency End-User Review Committee (ERC), composed of the Departments of Commerce, Defense, State, Energy, and the Treasury.

Beyond the Entity List, the U.S. government’s Military End Use / Military End User (MEU) regulations target U.S. exports to firms associated with the military, intelligence, and law enforcement entities of Burma, China, Russia, and Venezuela. 

• While BIS maintains a MEU List, the majority of the burden to identify MEUs falls on industry.

• Kharon’s research has identified tens of thousands of Chinese entities that may be considered MEU restricted under U.S. law, though do not appear on the MEU List.