China Adds 10 US Entities to Its Control List: MOFCOM Announcement No. 23 [2026] and the "Any Country or Region" Prohibition

This is Ryuta Hamamoto from TIMEWELL.

On 22 June 2026, China's Ministry of Commerce issued Announcement No. 23 [2026], placing 10 US entities on its export control list¹. I want to work through it from the original text, because the version that circulates in English-language summaries compresses it into "China restricts US companies" and loses the part that actually matters to exporters elsewhere.

That part sits in the first operative measure:

禁止任何国家和地区的组织和个人将原产于中国的两用物项转移或提供给上述实体

Organisations and individuals of any country and region are prohibited from transferring or providing Chinese-origin dual-use items to the listed entities. The prohibition is not addressed only to exporters inside China. If you are reading this from Tokyo, Stuttgart or Seoul, that sentence is the article.

One caveat belongs up front. Placement on a control list is a regulatory designation under that country's export control regime, not a judgment about the listed company. Announcement No. 23 says nothing about why any individual entity was designated. That is not my editorial restraint; it is the state of the document.

What Announcement No. 23 actually says

The title is 商务部公告2026年第23号 公布将10家美国实体列入出口管制管控名单的决定, dated 22 June 2026¹.

It cites the Export Control Law of the People's Republic of China and the Regulations on Export Control of Dual-Use Items as its basis, and states its purpose as safeguarding national security and interests and fulfilling international obligations including non-proliferation. That phrase is the standard statutory purpose language common to this instrument. It is not an assessment of any listed company, and conflating the two is where most misreadings of these lists begin.

There are two measures. The first prohibits Chinese export operators from exporting dual-use items to the 10 entities; prohibits organisations and individuals of any country and region from transferring or providing Chinese-origin dual-use items to them; and requires that ongoing related export activity stop immediately. The second provides that where export is genuinely necessary in exceptional circumstances, the export operator shall apply to the ministry. Prohibition as the rule, individual application as the exception.

On timing, the text says the announcement takes effect from the date of publication. That means 22 June, with no grace period and no expiry date stated¹.

If you need to check whether your own transactions are in scope: We publish a fill-in screening sheet that walks a single transaction through China's Export Control Law and Dual-Use Items Export Control Regulations, the announcements covering critical minerals and dual-use items, and all four counterparty-list systems (Control List, Watch List, Unreliable Entity List, countermeasure list). It is a procedure for what to verify before you trade, not a roster of who is listed, so the completed sheet becomes your internal record and the document you can share with a counterparty. Listing is a regulatory designation, not a judgment of the company. → Download the China-Related Transactions Export-Control Screening Sheet (2026) (Free. Your company name and work email are required.)

The 10 listed entities, as the annex gives them

Each annex entry has five fields: a serial number, the name (Chinese with the English in parentheses), 地址 (address), 邮编 (postcode) and 常用名称 — "commonly used names." That last field is the one that earns its keep in practice. In the order and spelling of the original¹:

#	Name (original)	地址 / address (original)	邮编	常用名称 / common names (original)
1	艾维奥克斯公司（Aveox, Inc.）	2265A Ward Ave., Simi Valley, CA, USA	93065	AVEOX
2	红猫控股公司（Red Cat Holdings, Inc.）	2800 S West Temple St., Unite 2, South Salt Lake, UT, USA	84115	Red Cat
3	蒂尔无人机公司（Teal Drones, Inc.）	2800 S West Temple St., Unite 2, South Salt Lake, UT, USA	84115	Teal Drones, iDrone
4	美国IMSAR公司（IMSAR, LLC）	940 S 2000 W#140 Springville, UT, USA	84663	IMSAR
5	杰亚机器人公司（Jaia Robotics, Inc.）	22 Burnside St Bristol, RI, USA	02809	Jaia Robotics
6	鲍尔航空航天技术公司（Ball Aerospace & Technologies Corp.）	10 Longs Peak Drive, Broomfield, CO, USA	80301	Ball Aerospace, Space & Mission Systems business of BAE Systems
7	奥什科什防务公司（Oshkosh Defense, LLC）	2307 Oregon Street, Oshkosh, WI, USA	54902	Oshkosh Defense
8	L3哈里斯海事服务公司（L3Harris Maritime Services, Inc.）	3835 E Princess Anne Rd, Norfolk, VA, USA	23502	L3Harris Maritime
9	芒廷帕斯材料公司（MP Materials Corp.）	1700 S Pavilion Center Drive Eighth Floor, Las Vegas, NV, USA	89135	MP Materials
10	美国稀土公司（USA Rare Earth, Inc.）	100 W Airport Rd, Stillwater, OK, USA	74075	USAR, USARE

The addresses run across California, Utah, Rhode Island, Colorado, Wisconsin, Virginia, Nevada and Oklahoma.

Note what the annex does not contain: there is no sector field and no reason field. Both that absence and the presence of the 常用名称 field matter again when we get to name matching.

The announcement does not say why

China's regime does set out grounds for designation in some detail. Article 28 of the Dual-Use Items Export Control Regulations gives three in its first paragraph (breach of end-user or end-use management requirements; potential harm to national security and interests; use of dual-use items for terrorist purposes) and two further categories in its second (use of dual-use items in the design, development, production or use of weapons of mass destruction and their delivery systems; having been subject to lawful measures prohibiting or restricting transactions or cooperation by the relevant state authorities)².

So the grounds exist and are enumerated. Yet the body of Announcement No. 23 contains only the general statutory purpose language. It does not say which ground applies to which of the 10 entities, makes no finding about any company's conduct, and alleges no violation¹.

I put this forward as a conclusion of fact-checking rather than as a courtesy. The text does not permit identification of any individual entity's grounds, so I will not speculate about them. What a listing does mean is that a verification step now stands between you and that counterparty. It is not a basis for assessing the company's business or standing negatively. Because lists from different jurisdictions get read as if they were one thing, it is worth keeping their differences in view: I set those out in Entity List, MEU List and SDN List compared.

"Any country or region": the wording gap with Announcement No. 27

The second half of the first measure is where non-Chinese companies come in, and the wording is not identical across announcements. Set No. 23 alongside No. 27 of 29 June 2026, which placed 20 Japanese entities on the control list¹³:

Point	No. 23 (10 US entities, 22 Jun 2026)	No. 27 (20 Japanese entities, 29 Jun 2026)
Prohibition on Chinese exporters	禁止出口经营者对上述10家实体出口两用物项	禁止出口经营者向上述20家实体出口两用物项
Who the extraterritorial ban addresses	任何国家和地区的组织和个人	境外组织和个人
Items covered	原产于中国的两用物项	原产于中华人民共和国的两用物项
Descriptive phrase in the opening	None ("艾维奥克斯公司等10家美国实体")	A collective descriptor (discussed below)
Activity that must stop	正在开展的相关出口活动应当立即停止	正在开展的相关活动应当立即停止 (no 出口)
Annex fields	Name, 地址, 邮编, 常用名称	Name, 地址, 邮编 (no 常用名称 field)
Exception	Application to MOFCOM where export is genuinely necessary	Same
Entry into force	Effective from the date of publication	Same

No. 27 says "outside China." No. 23 says "any country and region," a formulation that on its face does not exclude actors inside China either. I would not overload that difference with practical significance, but two announcements issued in the same month under the same regime describe their addressees differently, and you cannot see that unless you read the originals. English summaries render both as "entities outside China are also prohibited."

The addressee is not the only thing that moves. What must stop is "相关出口活动" (related export activity) in No. 23 and plain "相关活动" (related activity) in No. 27. The annexes are built differently too: No. 23 carries a 常用名称 field, No. 27 does not. Two announcements from the same bureau (安全与管制局) in the same month, and the format is not fixed. Summaries iron all of that flat.

Either way, the operative test is the same. Is the item a Chinese-origin dual-use item, and is the counterparty a listed entity? Your own nationality does not enter into it.

The exposure looks like this. A manufacturer or trading house sources components or materials from China, and those items fall within China's dual-use controls. Its US affiliate or distributor supplies one of the 10 listed entities, or supplies someone who counts a listed entity among its customers. In that chain, the non-Chinese company sits inside the announcement's scope.

The awkward part is that you cannot see this from your customer list. Even where no first-tier customer is listed, the route completes if goods move onward. And Chinese origin is procurement-side information that the sales side usually does not hold, so it only becomes visible when purchasing and sales data are read together.

On the extraterritorial architecture generally, see China's extraterritorial application and, for the regime as a whole, China's export control law framework. One limit worth stating: the announcement does not enumerate items, so what counts as a dual-use item turns on classification against the control list, which is a separate exercise covered in China's dual-use items list.

The governing provisions, by article number

The claim that Chinese announcements rest on thin legal ground does not survive contact with the texts. Nine provisions do the work⁴²:

Provision	Content
Export Control Law, Art. 18	Establishes the control list (three grounds) and the available measures: prohibiting or restricting transactions in controlled items, ordering exports to stop
Export Control Law, Art. 20	Prohibits providing agency, freight, delivery, customs clearance, third-party e-commerce platform and financial services for export control violations
Export Control Law, Art. 37	Penalties for transacting with a listed party
Export Control Law, Art. 44	Liability of organisations and individuals outside China that breach export control provisions
Regulations, Art. 13	Framework for prohibiting export of specified dual-use items, or export to specified destinations, organisations or individuals
Regulations, Art. 26	Effect of the watch list (no general licence, risk assessment report required)
Regulations, Art. 27	Five-year retention of end-user and end-use documentation, contracts, invoices and related records
Regulations, Art. 28	Grounds for placement on the control list
Regulations, Art. 29	Measures against listed parties, plus prior application, approval and post-transaction reporting for exceptions

The Export Control Law was promulgated on 17 October 2020 and took effect on 1 December 2020. The Regulations are State Council Order No. 792, promulgated 30 September 2024 and effective 1 December 2024.

The penalty arithmetic is worth stating plainly. Under Article 37, an export operator that transacts with a listed party faces warnings, orders to cease and confiscation of unlawful gains, and then a fine of 10 to 20 times the value of the unlawful business where that value is 500,000 yuan or more, or 500,000 to 5 million yuan below that threshold. In serious cases, qualifications to export controlled items can be suspended or revoked⁴. Because the fine scales as a multiple, the exposure grows with deal size.

Article 20 is the one people miss. Agency, freight, delivery, customs clearance, third-party e-commerce platforms and financial services are themselves prohibited where they support a violation⁴. That is not only a shipper's problem; freight forwarders, customs brokers, trading intermediaries and banks are all inside the frame. Article 44 then supplies the statutory footing for reaching parties outside China⁴.

One distinction to keep straight: the control list prohibits or restricts transactions in principle, with exceptions requiring prior approval and subsequent reporting, while the watch list leaves transactions permitted but removes general licences and registration-based export documentation and requires both a risk assessment report on the counterparty and a compliance undertaking at the single-licence stage. Article 26 also sets out how a party gets there: failure to cooperate with an end-user or end-use verification within the stated period, such that the end use cannot be established². "Do not, in principle" versus "more paperwork." And under Article 28(3), a watch-listed party can be moved up to the control list, so treating a watch listing as safe for the duration of a contract is a mistake worth avoiding.

Article 27's five-year retention duty cuts both ways. It is a burden, and it is also the only thing that lets you demonstrate later that you did check. The verification pattern itself is set out in end-user screening and customer due diligence.

The 2026 sequence: one framework, several jurisdictions

The ministry's 2026 announcement index makes clear that control-list designations are not aimed at a single country⁵.

Announcement	Date	Content
No. 1	2026-01-06	Strengthening dual-use item export controls toward Japan
No. 11	2026-02-24	20 Japanese entities added to the control list
No. 12	2026-02-24	20 Japanese entities added to the watch list
No. 20	2026-04-24	7 EU entities added to the control list
No. 23	2026-06-22	10 US entities added to the control list
No. 27	2026-06-29	20 Japanese entities added to the control list
No. 28	2026-06-29	20 Japanese entities added to the watch list
No. 30	2026-07-24	14 EU entities added to the control list

Tightened controls toward Japan in January, 20 Japanese entities plus 20 on the watch list in February, seven EU entities in April, 10 US entities in June, another 20 Japanese entities plus 20 in late June, 14 EU entities in July. One framework applied across the EU, the US and Japan, and for Japan twice within six months. I covered the February pair, Nos. 11 and 12, in China's dual-use export restrictions affecting Japan. Other instruments run alongside, including No. 24 (24 June 2026) promulgating measures for industrial and supply chain security reviews, No. 26 (same date) developing the handling of reports involving strategic mineral dual-use items, and No. 29 (10 July 2026, issued jointly by the ministry and the General Administration of Customs) imposing a temporary export ban on helium⁵.

On causation I will give the sequence and stop. The body of Announcement No. 23 makes no reference to any other jurisdiction's measures, and I was unable to obtain the ministry spokesperson's remarks or press briefing transcript for 22 June 2026. With no primary source establishing what the measure responds to, framings like "retaliation" have no place here. The useful point for companies is not who is right. It is that entities from any jurisdiction can end up in a regulatory designation, and that state of affairs is continuing.

Announcement No. 27 covers defence-equipment-related research institutes together with manufacturing and service companies, located in Tokyo, Kanagawa, Nagasaki, Aichi, Gifu and Saitama³. I am not going to reproduce the individual names here, because a bare list of names reads as a roster of problem companies whether or not that is intended.

One point of precision. No. 23 attaches no descriptor to its 10 entities, but No. 27 does place one in its opening: "决定将防卫研究所等参与提升日本军事实力的20家日本实体列入出口管制管控名单," a phrase applied collectively to all 20³. That is the issuing authority's characterisation of the designation in its own announcement, not a finding about which limb of Article 28 any individual entity falls under. No. 27's annex gives only names, addresses and postcodes, so there too nothing on the face of the list states a ground for any single entity. For the Japanese parties involved, this is not a failure of their own making but the consequence of state-level regimes intersecting above them. I cover that announcement in China's dual-use export restrictions affecting Japan.

Three reasons name matching fails

This is where the hours go. Reconciling 10 listed entities against your counterparty master is not a matter of exact-match search on company names, and reading the annex against each company's own filings shows why.

1. The formal name is a former legal name; the current one sits in the 常用名称 field. The sixth entry's formal name is 鲍尔航空航天技术公司（Ball Aerospace & Technologies Corp.）. BAE Systems announced on 16 February 2024 that it had completed the acquisition of Ball Aerospace from Ball Corporation and established the business as a new sector, Space & Mission Systems, adding more than 5,200 US employees⁶. So the formal-name field alone does not match how the business is known today.

The announcement, though, has accounted for that: the same entry's 常用名称 field reads "Ball Aerospace, Space & Mission Systems business of BAE Systems"¹. The trap is on the receiving end, not the issuing end. English and Japanese summaries, and most internal transcriptions, carry the company name and the address and nothing else. Build your matching table from the formal-name column only and you discard, by your own hand, the current name the announcement supplied. Entry 3's "iDrone" and entry 10's "USAR, USARE" are the same story: aliases you cannot derive from the formal name string. If you ingest the annex, ingest the 常用名称 field with it. This is a point about matching procedure, not a comment on the acquisition or on any company's business.

It is also a field you cannot count on. No. 27, from the same month, has no 常用名称 column at all. What handles you get differs announcement to announcement, so you have to look at what is actually there each time.

2. Parent and subsidiary appear at one address, and the suite number does not agree. Entries 2 and 3, Red Cat Holdings, Inc. and Teal Drones, Inc., both give 地址 "2800 S West Temple St., Unite 2, South Salt Lake, UT, USA" with 邮编 84115. SEC EDGAR gives Red Cat Holdings (CIK 748268, ticker RCAT) a business address of 2800 S West Temple, Suite 5, South Salt Lake, UT 84115⁷. Same street number, different suite, and "Unite 2" is the spelling in the original. Strict string matching on addresses will miss this.

3. Similar legal names exist within a group. The tenth entry, "USA Rare Earth, Inc.," matches the SEC registrant name (CIK 1970622, ticker USAR)⁸. But the company's own website also shows "USA Rare Earth, LLC" and "USA Rare Earth Magnets, LLC," and I do not have enough to determine which legal entity the announcement covers. Since I cannot settle it, I am saying so. In practice this is a question for counsel, not a call to make internally on the assumption that a similarly named affiliate falls outside scope.

There are handles to grip, though. Three of the 10 are US-listed, and the English names in the announcement match the SEC registrant names exactly: MP Materials Corp. (CIK 1801368, MP), USA Rare Earth, Inc. (USAR) and Red Cat Holdings, Inc. (RCAT)⁹. The addresses reconcile as well. The annex gives MP Materials "1700 S Pavilion Center Drive Eighth Floor, Las Vegas, NV" with 邮编 89135, the same location as the EDGAR business address "1700 S. Pavilion Center Dr., Suite 800, Las Vegas, NV 89135"¹⁰; and USA Rare Earth "100 W Airport Rd, Stillwater, OK" with 邮编 74075, matching EDGAR's "100 W Airport Road, Stillwater, OK 74075"⁸. For listed companies you can key the match to a CIK or ticker rather than relying on a name string.

I also checked Form 8-K filings around the listing date. Neither MP Materials nor Red Cat Holdings filed an 8-K addressing the designation in the days around 22 June¹⁰⁷. Whether an 8-K is required is a materiality judgment for each issuer, so the absence of a filing should not be read as an assessment of how either company responded. I am reporting the filing history, nothing more.

What the two rare earth entities say about themselves, and the supply-chain numbers

Two of the 10 could be described from their own primary disclosures, so here is what each says in its own words, without inference.

MP Materials Corp.'s FY2025 Form 10-K, filed 26 February 2026, opens Item 1 by describing the company as "the largest producer of rare earth materials in the Western Hemisphere," and its Mountain Pass mine and processing facility in San Bernardino County, California as "the only rare earth mining and processing site of scale in North America." It states that it manufactures metals, alloys and magnets at its Independence Facility in Fort Worth, Texas, and commenced manufacturing neodymium-iron-boron (NdFeB) permanent magnets in December 2025. Its reportable segments are Materials and Magnetics¹¹.

USA Rare Earth, Inc. describes itself on its own site as "Forging the future of critical minerals and advanced technologies — from mine to magnet and beyond," working with rare earth elements, oxides, metals and magnets, and states that it intends to "manufacture permanent magnets at scale"¹². Its EDGAR filings include an S-4/A on 23 June 2026 and a DEFM14A on 24 July 2026⁸.

What that supports is a plain reading: these are firms building a commercial mine-to-magnet supply chain in their own country. Legitimate commercial operators being caught by another jurisdiction's broadly drawn regulatory category is not a failing on their part. It is a consequence of how wide the dual-use category is.

For structural context, here are the USGS figures. This is an industry picture, not an assessment of any company¹³.

Indicator	Value (USGS Mineral Commodity Summaries 2026)
US mineral concentrate production (2025 est.)	51,000 t (REO equivalent), USD 240 million
Domestic production of compounds and metals	120 t (2021) → 95 t (2022) → 800 t (2023) → 4,300 t (2024) → 8,900 t (2025 est.)
Imports of compounds and metals	Up 169% by volume in 2025, while import value fell from USD 168 million (2024) to an estimated USD 165 million, which USGS attributes to a shift toward lower-value imported products
Net import reliance (compounds and metals)	53% (2024) → 67% (2025)
Import sources, compounds and metals (2021–24)	China 71% (incl. Hong Kong), Malaysia 13%, Japan 5%, Estonia 5%, other 6%
World mine production (2025 est.)	390,000 t total (China 270,000 / US 51,000 / Australia 29,000)
Reserves	China 44 million t, US 1.9 million t
Mining and processing employment (2025 est.)	670

Domestic output of compounds and metals has gone from 120 tonnes to roughly 8,900 tonnes in four years, while net import reliance has risen from 53% to 67%. Both can be true because demand and imports are growing faster still. Potential stockpile acquisitions for fiscal year 2025 included 300 tonnes of neodymium-praseodymium oxide, 450 tonnes of NdFeB magnet blocks and 60 tonnes of samarium-cobalt alloy, which puts a downstream product, magnets, inside the domestic sourcing perimeter¹³. The same publication records the trajectory of China's own controls (seven elements added in April 2025, five more in October, the October additions suspended for a year in November while the April controls remained, general licences issuing to selected exporters), a history I trace in the map of China's rare earth export controls¹³.

The discipline to hold here is not to join these facts causally. "They were listed because they anchor a rare earth supply chain" is not something the announcement says. I have two independent verified facts, the structure of the supply chain and the companies' own disclosures, and nothing that connects them.

What to do this week

Map your contact with the 10 entities. Direct customers, but also the sales books of US affiliates and the onward customers of agents and distributors. Key the match to more than the formal company name: use the annex's 常用名称 aliases, the addresses and postcodes, and CIK or ticker for the listed companies. Build in tolerance for former legal names and for spellings like "Unite" in the source. Because of Article 20, include transactions where you are only the forwarder, customs broker or settlement bank.

Establish whether you handle Chinese-origin dual-use items at all. That is procurement information. Is the source in China, and does the item fall within China's dual-use controls? Without it you cannot tell whether the announcement reaches you, and the sales side cannot answer it alone, which means purchasing and sales need to be in the same room.

Where a transaction is in flight, decide on stopping it first. The announcement requires ongoing related export activity to cease immediately. That collides with contractual obligations, so the sequence is to establish the facts and then take it to counsel. The application route to the ministry exists, but under Article 29 it is an approval regime and an exception, not a workaround.

Write it down. With Article 27's five-year retention in mind, record when you ran the match, against which list, against which master data, on what criteria. Verification you cannot evidence is verification you cannot explain later. In my experience the companies that skip this are the ones in difficulty six months on.

Build for the next round. Twenty Japanese entities in February, seven EU in April, 10 US and 20 Japanese in June, 14 EU in July: five rounds in six months. Expecting one compliance officer to spot a Chinese-language announcement on the day it posts and reconcile it against the customer master is not a system.

That gap is why we built TRAFEED to ingest regulatory updates from multiple jurisdictions on the day they land and match them against counterparty master data. As the world's first(*) AI agent for export control, it covers classification under list and catch-all controls alongside this kind of counterparty screening. The final classification and the decision on whether to transact remain with each company's export control officer. Our part ends at assembling the material behind that decision, completely, with sources, and fast.

What this article does not claim

The things I could not verify from primary sources, stated as unverified. What a piece leaves out is information too.

• The ground of designation for each of the 10 entities. Not stated in the announcement; which limb of Article 28 applies cannot be determined
• Any causal link to another jurisdiction's measures. The text makes no such reference, and I could not obtain the ministry spokesperson's remarks or press briefing for 22 June 2026
• Reports of a procurement ban covering 46 US companies. I reviewed the titles of MOFCOM's 2026 announcements from No. 1 through No. 30 and found no measure concerning government procurement. A measure by another authority is possible, but with no primary source in hand I am not folding it into an account of No. 23
• Statements from the listed entities. For Aveox, Teal Drones, IMSAR, Jaia Robotics, Oshkosh Defense, L3Harris Maritime Services and Ball Aerospace (now BAE Systems Space & Mission Systems), I could not obtain company releases or disclosures addressing the listing
• The precise scope of items covered, and delisting practice. The announcement does not enumerate items, so coverage turns on classification against the control list. Article 30 of the Regulations does provide a route to apply for removal, conditioned on cooperating with the ministry's investigation, ceasing the conduct, taking corrective measures and honouring undertakings given². What I could not find is any record of how that route works in practice, so I make no claim about prospects for removal

Summary

• On 22 June 2026, MOFCOM Announcement No. 23 placed 10 US entities on the export control list, effective the same day, with no grace period stated
• The second half of the first measure is what reaches companies outside China: organisations and individuals of any country and region are barred from transferring or providing Chinese-origin dual-use items to the listed entities. The test is whether the item is Chinese-origin dual-use and whether the counterparty is listed, not what nationality you hold
• Announcement No. 27 of 29 June (20 Japanese entities) addresses the same prohibition to parties "outside China," requires "related activity" rather than "related export activity" to stop, and has no 常用名称 field in its annex. Two announcements, one month, one bureau, and the drafting is not uniform
• The basis is Articles 18 and 44 of the Export Control Law with Articles 28 and 29 of the Regulations; penalties under Article 37 run to 10–20 times the transaction value above 500,000 yuan, and Article 20 reaches freight, customs and financial services
• Name matching does not end at company names: a formal name that is a former legal name (with the current one in the 常用名称 field), parent and subsidiary at one address, suite numbers that disagree, similar names within a group. Ingest the 常用名称 aliases, and for listed companies use CIK or ticker as the key
• Listing is a regulatory designation, not a judgment about the listed company. Announcement No. 23 states no grounds for any individual entity

One closing thought. The detail I kept returning to while writing this is that the announcement bothers to include a 常用名称 field at all. Whoever drafted it knew that matching goes wrong on names, and supplied the aliases. If the reader drops that column and settles for exact-match on the formal name, what survives is a record of a check that did not really happen. Read the list as a roster of bad actors and you will never notice the field is there. The 10 entities are companies going about their business in their own country, and firms elsewhere land in the same position under other jurisdictions' rules. So keep the axis of reading on what you are reconciling against what, rather than on who is at fault. It is unglamorous, and it is about the only way to end up able to explain your own decision months later.

If you are unsure whether your network touches any of the 10 entities, or where to start, talk to our TRAFEED team.

(*) As an AI agent in Japan's security export control domain covering list and catch-all regulations, confirmed by TIMEWELL internal research as of March 2026.

References and primary sources

Footnotes

1. Ministry of Commerce of the People's Republic of China, "商务部公告2026年第23号 公布将10家美国实体列入出口管制管控名单的决定," 22 June 2026 (main text and annex) https://www.mofcom.gov.cn/zcfb/blgg/gg/2026/art/2026/art_aab677e956c943808cebf8c06a28ff0e.html ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

2. Regulations of the People's Republic of China on Export Control of Dual-Use Items (State Council Order No. 792, promulgated 30 September 2024, effective 1 December 2024), Articles 13, 26, 27, 28 and 29 https://exportcontrol.mofcom.gov.cn/article/zcfg/gnzcfg/gzjgfxwj/202410/1057.html ↩ ↩² ↩³ ↩⁴

3. Ministry of Commerce of the People's Republic of China, "商务部公告2026年第27号 公布将20家日本实体列入出口管制管控名单," 29 June 2026 https://www.mofcom.gov.cn/zcfb/blgg/gg/2026/art/2026/art_6607ea694b704da8ac5e863a5568e47c.html ↩ ↩² ↩³

4. Export Control Law of the People's Republic of China, Articles 18, 20, 37 and 44 (promulgated 17 October 2020, effective 1 December 2020) https://exportcontrol.mofcom.gov.cn/article/zcfg/gnzcfg/flfg/202111/226.html ↩ ↩² ↩³ ↩⁴

5. Ministry of Commerce of the People's Republic of China, index of 2026 MOFCOM announcements https://www.mofcom.gov.cn/zcfb/blgg/gg/2026/index.html ↩ ↩²

6. BAE Systems, "BAE Systems completes acquisition of Ball Aerospace," 16 February 2024 (company release) https://www.baesystems.com/en-us/article/bae-systems-completes-acquisition-of-ball-aerospace ↩

7. US SEC EDGAR submissions API (Red Cat Holdings, Inc., CIK 748268) https://data.sec.gov/submissions/CIK0000748268.json ↩ ↩²

8. US SEC EDGAR submissions API (USA Rare Earth, Inc., CIK 1970622) https://data.sec.gov/submissions/CIK0001970622.json ↩ ↩² ↩³

9. US SEC EDGAR company_tickers.json https://www.sec.gov/files/company_tickers.json ↩

10. US SEC EDGAR submissions API (MP Materials Corp., CIK 1801368) https://data.sec.gov/submissions/CIK0001801368.json ↩ ↩²

11. MP Materials Corp., Form 10-K for FY2025 (filed 26 February 2026), Item 1 Business https://www.sec.gov/Archives/edgar/data/1801368/000180136826000008/mp-20251231.htm ↩

12. USA Rare Earth official website (company's own statements) https://usare.com ↩

13. U.S. Geological Survey, "Mineral Commodity Summaries 2026: Rare Earths," February 2026 https://pubs.usgs.gov/periodicals/mcs2026/mcs2026-rare-earths.pdf ↩ ↩² ↩³