The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule, “Adding Entities to the Entity List and Modifying Entries,” effective September 12, 2025. The rule adds 32 entities across multiple countries and regions to the Entity List, with over half being Chinese entities. Once added to the Entity List, these entities face strict export control restrictions: all exports, re-exports, or domestic transfers of items subject to the Export Administration Regulations (EAR) require BIS licenses. BIS applies “Presumption of Denial” or “Case-by-Case Review” policies, making license approval extremely difficult.

I. Main Content of the Final Rule

The final rule makes three key modifications to the Entity List:

1. Adds 32 new entities to the Entity List for participation in activities contrary to U.S. national security or foreign policy interests, with over half being Chinese entities or their overseas branches.

2. Updates information on one existing entity, removing two addresses of Russia’s Intertech Rus LLC.

3. Corrects spelling errors in 27 existing entries involving entities from Belarus (3), China (11), Iran (1), Pakistan (1), Russia (9), and Turkey (2).

II. New Listings and Reasons (by Destination)

China (23 entities):

1. National Time Service Center, Chinese Academy of Sciences: Listed for acquiring and attempting to acquire U.S.-origin items to support China’s military and defense-related space activities and quantum technology capabilities.

2. Beijing Fudan Microelectronics, Shanghai Fudan Microelectronics, Shenzhen Fudan Microelectronics, Shanghai Fuku Hikari Micro Systems, Shanghai Fuwei Quick Digital Technology, Shanghai Hualing Integrated Circuit Technology, and Shanghai Fudan Microelectronics (Hong Kong): Listed for acquiring U.S.-origin products to support China’s military modernization, advanced computing, and integrated circuit manufacturing, supplying China’s military, government, and security agencies. Shanghai Fudan Microelectronics and Shanghai Hualing were Footnote 4-designated for involvement in high-performance computing chip production, including AI applications, with Shanghai Fudan Microelectronics previously supplying technology to Russian military users.

3. Huake Logistics (HK), Huake Supply Chain (HK), Shenzhen Xinlikang Supply Chain Management: Listed for participating in transfers of dual-use items to sanctioned entities including the Iranian military.

4. Aerospace Information Research Institute, Chinese Academy of Sciences: Listed for affiliation with companies supporting China’s high-altitude balloon program.

5. Jimei Semiconductor Technology (Wuxi), Jicun Semiconductor Technology (Shanghai): Listed for acquiring U.S.-origin semiconductor manufacturing equipment for listed entities without BIS authorization.

6. Beijing Tianyi Huiyuan Biotechnology, Beijing Qiao Ke Biotechnology, Sangon Bioengineering (Shanghai): Listed for transferring U.S.-origin items to the PLA Academy of Military Sciences posing unacceptable risk.

7. Shanghai Suchen Information Technology, Hong Kong Suchen Information Technology: Listed for developing CAE software for China’s military-industrial complex, including listed clients.

8. Changsha Nanfei Microelectronics, Changzhou Nanfei Microelectronics, Chengdu Nanfei Microelectronics, Shenzhen Nanfei Microelectronics: Listed for export control evasion and transfers to listed entities.

Singapore (1), Taiwan (1), India (1), Turkey (3), Iran (1), UAE (2)

For most newly listed entities, BIS requires licenses for all EAR-controlled items, with Footnote 3 and Footnote 4 designations extending controls to certain foreign-produced items containing U.S. technology.

III. Key Trends: Precision Targeting

The update demonstrates highly targeted precision against China’s high-tech sectors:

This reflects the U.S. strategy of controlling China’s access to critical technologies. Footnote 4 restrictions extend the Foreign Direct Product Rule (FDPR) to additional advanced computing and semiconductor entities. Third-country transshipment routes are also being targeted, with entities in Singapore, Taiwan, Turkey, India, and UAE listed for alleged support to Iranian and Russian military procurement networks.

IV. Potential Impact

For Chinese Tech Enterprises: Immediate supply chain disruption for listed entities, with long-term acceleration of technology self-sufficiency.

For Global Supply Chains: All businesses dealing with listed entities must conduct rigorous due diligence and comply with EAR, increasing global trade compliance costs.

Future Trends: BIS is expected to employ increasingly precise export control measures targeting biotechnology, AI, and quantum technology sectors.