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A Law Requiring Cooperation with the Military

The 2017 National Intelligence Law is the cornerstone of China’s military-civilian fusion doctrine. Article 7 stipulates that “all organizations and citizens shall, in accordance with the law, support, assist, and cooperate with the state’s intelligence work.” This obligation is unconditional—it does not depend on the company’s willingness, its listing on the New York Stock Exchange, or its commercial commitments to Western partners. The law is clear: if the state requests it, the company must comply. This legal reality lies at the heart of the 1260H designation: the Pentagon does not claim that Alibaba manufactures missiles. It states that Alibaba operates under a legal framework that requires its cooperation with the military upon request.

The doctrine of military-civil fusion dates back to Deng Xiaoping’s reforms in the 1980s but was systematized and institutionalized under Xi Jinping beginning in 2015. It aims to transform the civilian economy into a technological reservoir for the military—a reversal of the American “spin-off” logic, where military technologies generate civilian applications. In China, the opposite is true: private investment in civilian technologies (AI, robotics, biotechnology, advanced materials) is intended to fuel military capabilities. It is an innovation model that harnesses the dynamism of the private sector while ensuring that its most strategic fruits remain accessible to the state. And it is precisely this model that the 1260H list seeks to contain.

What the 1260H designation actually does

The 1260H designation is not a sanction in the traditional sense. It operates on several levels. First, it prohibits direct contracts between the Pentagon and designated companies—meaning that Alibaba Cloud, Baidu AI Cloud, or BYD’s autonomous vehicles can no longer be used in the Department of Defense’s infrastructure or operations. Second, starting in 2027, it extends to subcontractors—creating cascading pressure across the entire U.S. defense supply chain to identify and eliminate dependencies on designated entities. Third, it sends a powerful political signal: being on this list damages a company’s international reputation, discourages partnerships with Western firms, and complicates access to the markets of NATO allies who follow Washington’s lead.

The contagion effect is real. Once a company is on the 1260H list, U.S. banks become more cautious, business partners assess the legal risk, and lobbyists—as we saw on June 30, 2026—terminate their contracts. This systemic pressure is no accident: it is designed to increase the cost of being designated, in the hope of influencing the behavior of Chinese companies—or at least restricting their access to the U.S. economic ecosystem.


The 1260H list is a flexible weapon. It does not destroy Chinese companies—it gradually isolates them. And gradual isolation, in a world of economic interdependence, is often more devastating than direct sanctions. It is a strategy of institutional attrition.

This content was created with the help of AI.

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