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.
Alibaba vs. the Pentagon: An Unprecedented Legal Battle
The complaint filed on June 24, 2026, with the federal court in San José
Alibaba did not accept its designation without a fight. On June 24, 2026, the company filed a lawsuit in the U.S. District Court for the Northern District of California in San José, challenging its designation as a Chinese military company. Alibaba’s central argument is that the designation “has no basis in fact or law.” The company maintains that it does not manufacture weapons, does not provide military services, and has no contractual relationship with the People’s Liberation Army. It denounces the decision as an arbitrary administrative action that harms its legitimate business activities without any evidence of an actual contribution to the Chinese military machine.
This legal battle is not entirely unprecedented—WuXi AppTec also challenged its designation in the District of Columbia court. But Alibaba’s size and the high-profile nature of its case make this the most significant confrontation. The court will have to rule on a fundamental question: How far can the U.S. government go in designating a foreign private company as a military actor, based on a foreign doctrine (China’s military-civil fusion) rather than on the company’s actual actions? The answer to this question will have implications far beyond the Alibaba case—it will define the legal boundaries of U.S. technological decoupling.
Alibaba’s Argument and Its Limitations
The argument that there is no direct relationship with the military is legally sound but politically fragile. Alibaba can prove that it does not sell directly to the PLA. But it cannot erase the existence of the 2017 law requiring mandatory cooperation with national intelligence agencies. Nor can it deny that its cloud data—potentially including information on millions of foreign users, commercial transactions, and corporate communications—represents a potentially valuable intelligence asset for the Chinese state. The question is not what Alibaba is doing today. The question is what Chinese law will compel it to do tomorrow, if the state demands it.
The case of DJI, the drone manufacturer, is illustrative. DJI lost its legal challenge to the Pentagon’s list and is currently appealing. DJI, too, claimed it was not a military company. But DJI’s civilian drones have been used extensively in Ukraine and Russia—demonstrating precisely the dual-use argument that justifies the designations. Civilian technology becomes military without the company deliberately choosing it—the logic of the battlefield prevails. That is the Pentagon’s argument. And so far, the courts have accepted it.
Alibaba says, “No ties to the military.” Washington responds, “No need—Chinese law requires you to do so if asked.” This isn’t a matter of concrete evidence. It’s a matter of the system. And when it comes to the system, the Pentagon has a strong case.
BYD and NIO: When Electric Cars Become Strategic
Batteries that power tanks, data that maps territories
The inclusion of BYD and NIO highlights the most counterintuitive aspect of the 1260H list: automakers on a military list. But the argument isn’t about the cars themselves—it’s about three crucial technological dimensions. First, battery technology: BYD is one of the world’s largest manufacturers of lithium iron phosphate batteries, a technology directly applicable to military vehicles, energy storage systems for remote operations, and long-endurance drones. BYD’s superiority in batteries is not just a commercial advantage—it is a strategic one.
Second, mapping and navigation data: BYD and NIO vehicles continuously collect data on roads, buildings, and traffic patterns—real-time mapping that could be useful for military operations. In China, this data is subject to national security laws that require it to be shared with authorities upon request. In foreign markets where these vehicles operate—including Europe—the issue of data sovereignty becomes directly relevant to national security. Third, autonomous driving technologies: the development of perception, navigation, and decision-making systems for civilian vehicles is directly transferable to autonomous weapons systems—ground drones, autonomous armored vehicles, and military logistics systems.
Europe Faces the Dilemma of Chinese Electric Cars
The U.S. designation of BYD creates an acute political dilemma for Europe, which simultaneously needs affordable electric cars to meet its climate goals and faces growing pressure from its American allies to reduce its dependence on sensitive Chinese technologies. The European Union imposed additional tariffs on Chinese electric vehicles in 2024, but BYD and other Chinese manufacturers continue to expand into the European market, including by building factories in Hungary and considering sites in France and Spain.
If the Pentagon’s arguments regarding dual-use technology are valid—and national security analyses by the U.S. and several NATO allies suggest they are—then the massive presence of BYD vehicles on European roads is not neutral from a security standpoint. It creates data-collection infrastructure and maintenance networks that could be compromised, as well as technological dependencies that complicate any future decoupling. This is the kind of vulnerability the United States sought to avoid with its designation—and which Europe, pressed by its climate imperatives, has been less quick to anticipate.
BYD makes the best electric cars at the lowest price. Europe wants to decarbonize its vehicle fleet. But if these cars map roads, collect data, and operate under a law that requires cooperation with Beijing—are we accepting an invisible security trade-off with every charge? I don’t claim to have the answer. But the question deserves to be asked frankly.
Lobbying in Washington: An Orderly Retreat
BGR, Brownstein, Mercury: Major Firms Are Jumping Ship
June 30, 2026, was the deadline set by the Pentagon’s new rule: lobbyists representing companies on the 1260H list could no longer enter into contracts with entities within the Department of Defense. The response from K Street—the symbolic hub of Washington lobbying—was immediate and telling. BGR Group terminated its $140,000 contract with Alibaba on June 30, to the day. In the two weeks prior, M/O Strategies, Story Partners, Mercury Public Affairs, Sidley Austin, Greenberg Traurig, and Brownstein Hyatt Farber Schreck had all terminated their contracts with Alibaba. The same firms had also dropped Tencent. BYD, for its part, had filed a notice of termination with the Foreign Agents Registration Act (FARA) registry.
This exodus of lobbyists is not merely a matter of legal compliance. It is a market signal. These firms have calculated that the revenue generated by Chinese contracts—substantial, but not extraordinary relative to their overall portfolios—is not worth the reputational risk, the potential legal complications, and the pressure from government clients who view representatives of entities on the 1260H list with suspicion. When Washington’s best-connected firms make this calculation, they send a signal to Chinese companies themselves: political access to the U.S. administration is closing off. And without political access, it is much more difficult to challenge designations, influence regulations, or maintain government partnerships.
Congressional representatives are pushing to go further
The pressure isn’t coming solely from the executive branch. Representatives John Moolenaar (R-MI), chairman of the House Select Committee on China, and Elise Stefanik (R-NY) sent a letter to Secretary of Defense Pete Hegseth urging strict enforcement of the rule, particularly by preventing designated companies from circumventing restrictions through subsidiaries or third-party entities. This bipartisan pressure—which in this context is primarily Republican but enjoys broad Democratic support on the issue of China—suggests that the 1260H list will continue to expand, not shrink.
The political landscape in Washington on the issue of China is one of the few areas of consensus. Democrats and Republicans may disagree deeply on almost everything—but on the need to contain Beijing’s technological and military expansion, there is broad agreement. This means that Chinese companies cannot hope that a change in administration will reverse the trend. The 1260H list is structurally politically stable—and likely to grow in the coming years.
Moolenaar and Stefanik are writing to Hegseth to ensure the list is strictly enforced. K Street is shunning Chinese clients. The bipartisan consensus holds. This is not a Trump administration policy—it is U.S. policy. And this continuity is the most important thing to understand.
Beijing's response: counter-sanctions and symmetrical escalation
June 22, 2026: Beijing Blacklists 10 U.S. Defense Companies
China did not stand idly by. On June 22, 2026, the Chinese Ministry of Commerce blacklisted 10 U.S. defense companies—including MP Materials, the largest U.S. producer of rare earths, and USA Rare Earth. These Chinese designations prohibit the targeted companies from doing business with Chinese counterparts, impose export restrictions on them regarding China, and signal to global trading partners that Beijing considers these entities to be adversaries. That same week, China barred 46 U.S. companies from accessing its government procurement markets—a measure that adds to the restrictions already in place on imports and investments.
The symmetry is deliberate. Beijing is sending a clear message: for every Chinese entity blacklisted by Washington, there will be a response. This logic of reciprocal escalation is not new in Sino-American relations—it is reminiscent of the 2018–2019 tariff trade war. But in the realm of military designations, it introduces a new dimension of risk: if every designation triggers a counter-designation, technological decoupling accelerates exponentially, and the economic costs for both sides rise accordingly. The question is which side will be better able to bear these costs—and Washington is betting that China, which is more dependent on Western technologies, will give in first.
Rare Earths: The Structural Threat from China
The designation of MP Materials and USA Rare Earth is no trivial matter. China controls approximately 60% of global rare earth production and more than 80% of the processing capacity for these critical minerals. Rare earths are essential for the manufacture of AI chips, batteries, electric motors, and guided weapons systems. By targeting U.S. companies seeking to develop alternatives to Chinese dependence, Beijing is attempting to slow down U.S. diversification efforts and maintain its structural advantage in the supply chain for critical technologies. This strategy is rational—and it will work as long as U.S. and allied investments in alternative rare earths remain insufficient.
The rare earths war is one of the least visible but most important dimensions of the Sino-American technological competition. Without access to the minerals that China controls—or to alternatives developed domestically or by allies—the production of chips, batteries, and advanced weapons systems is limited. Beijing’s designation of U.S. rare earth companies is therefore a strategic response to the 1260H list: you target my tech giants, I target your ability to break free from me.
Beijing has blacklisted MP Materials—the largest U.S. producer of rare earths. This is not merely symbolic. It is a threat to the supply chain for everything that matters: AI chips, batteries, and guided missiles. China isn’t retaliating with words—it’s targeting the very foundations.
WuXi AppTec and the Pharmaceutical Industry: Biology in the Technology War
Why Is a Pharmaceutical Contract Manufacturer on a Military List?
WuXi AppTec is perhaps the most surprising entry on the 1260H list. The company is a global pharmaceutical contractor: it helps American and European pharmaceutical companies develop and manufacture drugs. Dozens of major Western pharmaceutical companies use its services. Why is it on a military list? The answer lies in the field of biotechnology: WuXi AppTec’s work in chemical synthesis, genomic sequencing, and molecular biology research is fundamentally dual-use. These capabilities—used today for drug development—are indistinguishable from those needed to develop biological agents or chemical weapons tomorrow, should an institution decide to repurpose them.
The Pentagon’s argument is not that WuXi AppTec is developing biological weapons. The argument is that its expertise, equipment, genomic databases, and legal obligations to the Chinese government make it a potential participant in a military biological program should Beijing decide to launch one. This preventive logic is difficult to challenge from a security standpoint—but it is deeply destabilizing for global pharmaceutical supply chains that rely on WuXi AppTec. The company has challenged its designation in the U.S. District Court for the District of Columbia—with less media attention than Alibaba, but with stakes just as high for the rules governing biotech decoupling.
Implications for the Global Pharmaceutical Supply Chain
WuXi AppTec’s designation forces major pharmaceutical companies to choose: either they maintain their relationship with this crucial contractor and risk complications in their contracts with the Pentagon and U.S. government agencies, or they sever partnerships that took years to build and seek out more expensive and less experienced alternatives. This choice illustrates a real cost of technological decoupling that policymakers rarely acknowledge: decoupling is not free; it redistributes considerable economic costs, and it is often the most integrated supply chains—pharmaceuticals, semiconductors, electronic components—that bear the heaviest burden.
These costs are real and significant. They do not refute the security rationale behind the 1260H list—but they do require that it be applied with discernment and accompanied by investments in domestic or allied alternatives. A designation that isolates a Chinese company without creating a viable substitute secures nothing—it creates a shortage. And shortages in the pharmaceutical or semiconductor supply chains have direct consequences for civilian populations who have nothing to do with Sino-American geopolitical competition.
WuXi AppTec is on the list. U.S. pharmaceutical companies that use its services are now calculating the cost of the disruption. Some will not be able to afford it in the short term. This is the true face of decoupling: bureaucrats signing executive orders, and engineers and researchers who must rebuild years of trust in a matter of months.
Unitree Robotics: Robot Dogs for Future Warfare
From the Living Room to the Battlefield: The Double Life of Quadruped Robots
Unitree Robotics is perhaps the least surprising entry on the 1260H list. The company manufactures quadruped robots—those four-legged mechanical creatures that resemble metal dogs—used in industrial settings, research, and… the military. Videos released in 2024 and 2025 showed soldiers from the People’s Liberation Army training Unitree robots equipped with small arms in urban combat scenarios. These images circulated on global military social media and directly contributed to the decision to designate the company. Unlike Alibaba or BYD, Unitree cannot claim to have no military ties—the evidence is on YouTube.
Robotics is one of the fields where dual-use applications are most obvious. A quadruped robot capable of navigating rough terrain, opening doors, carrying loads, and maintaining its balance under difficult conditions is precisely what an army needs for operations in urban areas, mountainous terrain, or environments where human casualties would be unacceptable. The civilian and military versions of the same robot differ only in the equipment attached to them. Unitree sells the platform—military customers attach the weapons. This logic makes its classification difficult to dispute.
Chinese Military Robotics: Current Status
Beyond Unitree, China has an ambitious military robotics program that incorporates reconnaissance robots, swarm drones, autonomous ground vehicles, and amphibious systems. The 295 billion AI plan directly fuels this program: AI is the central nervous system of military robots—without it, they are remote-controlled machines; with it, they become semi-autonomous weapons systems capable of making tactical decisions in contested environments. Analyst Rick Fisher has documented that these capabilities are likely incorporated into plans for an invasion of Taiwan as an initial phase to suppress coastal defenses.
Unitree’s designation on the 1260H list sends a signal to other civilian robot manufacturers who might be tempted to sell their platforms to Chinese military entities: exporting these technologies, collaborating with designated companies, or even selling civilian robots with documented military applications carries consequences. This is preventive logic in action—and in the field of robotics, where the line between civilian and military is particularly thin, this logic is hard to dispute.
Unitree’s robot dogs, shown in PLA videos being trained while armed, are now on the Pentagon’s blacklist. It’s hard to argue with that. What strikes me is the question of the other Unitree robots that aren’t yet on the list—the ones that haven’t posted a video yet.
Geopolitical Implications: From the List to the War of Standards
Whoever controls technological standards controls the world
The 1260H list is a defensive tool—it protects U.S. markets and infrastructure from Chinese entities deemed strategically risky. But its geopolitical scope extends beyond defense. It is part of a broader battle for control over global technology standards. Whoever sets the standards for AI, robotics, autonomous vehicles, 5G and 6G networks, and cybersecurity protocols shapes the technological architecture within which the world will operate for decades to come. These standards determine who can interoperate with whom, what data flows and how, and who can code backdoors into critical systems.
China is actively encouraging its companies—including several on the 1260H list—to contribute to international technology standards organizations: ITU, ISO, and IEEE. It seeks to have its protocols adopted as global standards in areas where it has a strong presence—surveillance AI, facial recognition, autonomous vehicles, and smart cities. If these standards are adopted by developing countries that are equipping themselves with Chinese technologies, Beijing’s influence will spread into the very architecture of the global internet. The 1260H list complicates this strategy—but it does not neutralize it in countries that do not enforce U.S. designations.
The Allies’ Dilemma: Follow Washington or Preserve Their Trade Relations
NATO and Quad allies find themselves in an uncomfortable position. In theory, they share U.S. concerns about China’s military-civilian fusion and the risks posed by designated companies. But they also have significant trade ties with China—Germany sells cars, France exports aerospace and luxury goods, and Japan and South Korea are deeply integrated into Chinese electronics supply chains. Adopting U.S. designations without nuance risks triggering trade countermeasures from Beijing that would hurt their economies.
This dilemma lies at the heart of Western alliance policy on the issue of China. The United States is moving forward with unilateral measures—the 1260H list, export controls, investment restrictions—and hopes that its allies will follow suit, at least in part. But alignment is not automatic. It requires difficult political coordination, economic compensation for sectors suffering from decoupling, and clear communication about the real risks posed by designated companies. Without this political work, U.S. measures achieve only part of their objective: they protect U.S. markets but leave allies exposed to the same risks.
Germany buys BYD products. South Korea manufactures its chips using ASML machines that incorporate Chinese components. Japan is hesitant. NATO allies want both U.S. security and access to Chinese markets. This is no longer tenable—and everyone knows it, yet everyone pretends not to.
Technology as a Battlefield: The Ukrainian Precedent
What Ukraine Has Learned About Technology in Wartime
The war in Ukraine has provided a brutal lesson on the role of technology in modern conflict. Ukrainian and Russian FPV drones, AI-assisted targeting systems, Starlink satellites, and electronic warfare systems—all of these have transformed a conventional conflict into an open-air technology laboratory. And in this laboratory, the ability to innovate quickly, deploy on a massive scale, and adapt to enemy countermeasures is just as decisive as traditional firepower. Ukraine has survived in part because it has benefited from Western technologies—secure communications, real-time intelligence, and advanced missile defense systems. Russia, under sanctions, has had to source technology from its allies—including China.
If China succeeds in building the AI infrastructure promised by its 295 billion plan, its technological support for Russia will be qualitatively different from what it is today. It will be able to provide AI targeting systems, autonomous swarm drones, and electronic warfare tools that are more effective than anything Russia can develop on its own. This scenario is not hypothetical—it follows directly from the logic of the Chinese plan and the China-Russia strategic partnership policy. And List 1260H is an attempt to limit the speed at which this scenario can materialize.
List 1260H as a Doctrinal Tool, Not Just a Legal One
Viewing List 1260H solely as a legal instrument—who can challenge it, under what procedures, and with what arguments—misses the point. It is first and foremost a doctrinal instrument. It tells the world that the United States considers the distinction between private companies and military actors to be no longer relevant in the context of Xi Jinping’s China. It sets a precedent that will gradually be adopted by allies, incorporated into investment regulations, and applied to public procurement. It creates an exclusionary framework that, over the next decade, will progressively isolate Chinese entities from Western technological, financial, and governmental ecosystems.
This doctrine has implications far beyond China. It raises the question of how democracies will manage their relationships with non-democratic economies in the era of AI and autonomous weapons systems. The response being developed by the United States is through designation, selective decoupling, and the strengthening of alliance standards. It is an imperfect doctrine, with real economic costs and documented risks of escalation. But it is also the only structured response that has emerged in the face of an unprecedented challenge.
List 1260H is not perfect. It is costly for allies. It forces painful choices. But it is the doctrine of the only country that has decided to face the problem head-on and act accordingly. While others negotiate exemptions, Washington is building an architecture of resistance. Imperfect—but real.
Companies Under the Microscope: Risk Profile by Sector
Cloud Computing, AI, and Data: Alibaba and Baidu
Alibaba Cloud is the world’s third-largest cloud provider, behind Amazon Web Services and Microsoft Azure. Its infrastructure spans dozens of countries, including several U.S. allies. Baidu is China’s leading search engine and one of the country’s most advanced AI companies, with language models (Ernie Bot), autonomous driving systems (Apollo), and massive cloud services. In both cases, the specific risk involves access to data: foreign users’ data hosted on their infrastructure, browsing and behavioral data collected by their systems, and intellectual property stored in their clouds. Under China’s 2017 law, this data is accessible to the government upon request.
Migrating from Alibaba Cloud to AWS or Azure is no small task for companies that have built their systems on top of it—but it is feasible, and the 1260H designations are creating strong pressure to accelerate this migration. The risk is different for Baidu: its search engine, widely used in China, collects data on the searches of millions of users—including foreign nationals traveling or working in China. This data can have considerable intelligence value. And Baidu’s AI models, trained on vast amounts of textual and visual data, can be used to generate disinformation on a large scale.
Biotechnology, Robotics, and Autonomous Vehicles: The Specter of Dual-Use
WuXi AppTec, Unitree Robotics, BYD, and NIO represent three dimensions of the dual-use problem. WuXi’s biotechnology is dual-use because its chemical synthesis and genomic sequencing capabilities are fundamentally neutral—they can be used to treat patients or to develop pathogens. Unitree’s robotics is dual-use because the mechanical platforms are identical; only the attached equipment differs. BYD’s and NIO’s autonomous vehicles are dual-use because the perception, navigation, and decision-making technologies are directly transferable to autonomous ground-based weapons systems.
This spectrum of dual-use applications is the central challenge of designation policy: there is no clear, universally accepted line between civilian and military use in advanced technologies. Each designation requires a judgment on the acceptable level of risk, the probability of military transfer, and the economic costs of decoupling. The Pentagon—and its counterparts among allies that enforce similar policies—must make these judgments with incomplete information about Beijing’s true intentions, in a political environment where the costs of underreaction (an enemy weapons system built with Western components) are asymmetrically more severe than the costs of overreaction (loss of commercial revenue and economic friction).
Dual-use: the term that justifies everything. I understand the logic. I even accept it in obvious cases like Unitree. What concerns me is the slippery slope—if everything can be dual-use, then everything can be designated. And a list of 188 companies today could become 800 tomorrow. Principles need safeguards.
The U.S. Industrial Response: Investments, Substitutions, and the Race
The CHIPS Act, DARPA, and the Rebuilding of Technological Sovereignty
The 1260H list only makes sense if it is accompanied by investments in domestic alternatives. This is the logic behind the CHIPS and Science Act of 2022—$52 billion to rebuild U.S. semiconductor manufacturing capacity—and DARPA, which funds research in military AI, autonomous robotics, and advanced materials. These investments are real and significant, but they take time: a state-of-the-art semiconductor factory takes five to seven years to build and bring online. Today’s investment decisions will determine our capabilities in 2030.
The risk of the U.S. strategy lies precisely in this time lag: the 1260H designations are creating disruptions in supply chains today, but domestic or allied alternatives will not be available for several years. In the meantime, U.S. companies—particularly in the pharmaceutical and electronics sectors—find themselves in an uncomfortable position: cutting ties with designated Chinese entities weakens them commercially, but maintaining those ties exposes them to legal and reputational risks. This transitional gap is the strategy’s weak point, and Beijing is fully aware of it.
The Challenge for Allies: The Need for a Common Industrial Strategy
An effective response to the 1260H list and the risks it aims to contain cannot be solely American. It requires a coordinated industrial strategy among technological democracies—the United States, Europe, Japan, South Korea, Australia, and Canada—to jointly develop alternatives to Chinese technologies in critical sectors: semiconductors, batteries, industrial robots, biotechnology, and sovereign cloud computing. Such coordination already exists to some extent—within the Quad, in NATO+ discussions on technology, and in bilateral technology-sharing partnerships. But it is still not systematic enough and is underfunded to constitute a structural response to the scale of China’s 295-billion plan.
Ultimately, what the 188 designations on the 1260H list tell us is that technological competition with China is now systemic—it affects nearly every sector of the modern economy. Managing this competition effectively requires a coherent vision that transcends electoral terms, a capacity for public investment that rivals that of the Chinese state, and an alliance-based solidarity that transforms partners into co-builders of technological sovereignty. This is a governance challenge for democracies—and their ability to meet it is itself a test of their viability in the face of authoritarian systems.
188 designations. A growing list. Hesitant allies. Weakened supply chains. And meanwhile, China is building its own sovereign infrastructure, out of reach. The 1260H list is not a policy—it is a wake-up call. The policy has yet to be formulated.
The Future of the List: Trajectory and Scenarios
Around 300, 400, or 500 entries?
The 1260H list has grown from a few dozen companies to 188 in just a few years. The logic behind its expansion is inherent in its design: if China’s military-civil fusion policy applies to all strategic sectors, then the potential number of companies eligible for designation is very large. The inclusion criterion—contributing to China’s defense industrial base through dual-use technology—applies to thousands of Chinese companies active in semiconductors, communications, drones, advanced materials, biotechnology, and energy systems. The list of 188 is a selection, not a cap.
Several factors could accelerate its expansion. An escalation of tensions surrounding Taiwan—particularly a show of military force—would likely trigger a rapid expansion of the list. Documented evidence that non-designated companies are supplying technology directly to the PLA would have the same effect. A Supreme Court ruling upholding the existing designations in the Alibaba and WuXi cases would strengthen the legal basis for future expansions. Conversely, a breakthrough in Sino-American diplomatic negotiations on technological arms control—unlikely in the short term—could stabilize or shrink the list.
Irreversible Decoupling and the New Global Architecture
The most likely trajectory over the next five years is a gradual but accelerating technological decoupling between the U.S./allied and Chinese ecosystems. This decoupling is not total—trade will continue in non-strategic sectors—but it is fundamental in critical technologies. Two distinct global technological ecosystems are emerging: one centered on U.S. and allied standards, platforms, and supply chains; the other on Chinese standards, platforms, and AI infrastructure. Developing countries will have to choose which one to integrate into—a choice with lasting geopolitical consequences.
The 1260H list is one of the instruments driving this divergence. It is neither the cause nor the solution—it is a symptom of systemic competition between two incompatible visions of the relationship between the state, business, technology, and national security. Understanding what it means—beyond individual designations, beyond legal battles, beyond commercial gains and losses—is essential to understanding the world that is taking shape. And this world is being built right now—in the courtrooms of San José and Washington, on Alibaba Cloud’s servers and in Baidu’s data centers, in Unitree’s robotics labs and BYD’s battery factories. It is being built in real time. And its architecture will determine the security of our democracies for decades to come.
Two technological ecosystems. Two worldviews. Two architectures for the internet, AI, robotics, and biology. And in the middle: countries that will have to choose. This isn’t the Cold War—it’s something more diffuse, more profound, and potentially more enduring. History offers no exact precedent for what we are experiencing.
Ukraine, Technology, and the Struggle for Democracy: What List 1260H Means for Kyiv
Technology on the Front Lines of Hybrid Warfare
The war in Ukraine is not just a conflict of tanks and artillery. It is also a war of AI-powered drones, electronic warfare, secure communications, and real-time geospatial intelligence. Ukraine’s technological advantage—its access to Western systems—has offset part of Russia’s numerical advantage. Elon Musk’s Starlink satellites, targeting systems shared by allies, and drones developed by Ukrainian engineers—all of these have made a measurable difference on the ground. And that difference would not exist if the underlying technologies were freely available to Russia and its suppliers, including China.
The 1260H list is therefore, to a certain extent, a tool for protecting Ukraine. By limiting Chinese companies’ ability to access U.S. technology markets and draw on innovations there, it slows down the potential transfer of technology to Russia via China. This link is indirect—there is no documentation proving that Alibaba supplied technology to the Russian military. But the systemic logic is real: a China that is more integrated into Western technology ecosystems is a China better equipped to support its strategic partners, including Russia. And a China that is singled out and isolated is a China whose technology transfers to Moscow are more visible and more easily subject to sanctions.
What Kyiv Expects from Washington on the Technology Front
Kyiv is watching the Sino-American technology war with direct and urgent interest. Every designation of a Chinese company specializing in military AI, robotics, or communications is potentially a limitation on the capabilities that China could transfer to Russia. Every U.S. investment in alternatives to Chinese technologies is potentially a technology that Washington can share with its allies, including Ukraine. The 1260H list is not designed to protect Ukraine—but its unintended consequences are moving in the right direction.
This link between U.S. technology policy and Ukrainian security deserves to be made explicit. It rarely is, because U.S. economic security policy and the policy of supporting Ukraine are managed by different agencies, each with different rationales. But at the strategic level, the coherence is there: containing Chinese technological power and supporting Ukrainian resistance against Russian aggression are two aspects of the same project—preserving an international order in which democracies can defend themselves, cooperate, and define the rules of the technological game.
Ukraine and the 1260H list. The connection isn’t obvious—it’s systemic. Every Chinese company cut off from U.S. technology is one less company capable of supporting Russia’s war effort. That isn’t the official reason for the designations—but it is one of their real consequences. And in Kyiv, they know it.
Conclusion: 188 names on a list—and what they reveal
What the list says about us as much as it does about them
The 1260H list, with its 188 companies, reveals something fundamental about the state of Sino-American relations in 2026: trust is dead. Not the trade relationship—that continues, with all its tensions and compromises. Not the diplomatic negotiations—they continue, despite everything. But the institutional trust that private companies can operate outside the logic of state power, that technologies can be shared regardless of their potential military use, that economic interdependence automatically generates political convergence—that trust is dead. The 1260H list is its death certificate.
This death of trust is not an arbitrary decision by the Trump administration or its predecessors. It is the result of the evolution of China’s political and economic model under Xi Jinping: from the reaffirmation of the Communist Party’s leading role in the economy, to the enactment of laws mandating cooperation with the state, to the construction of an unprecedented surveillance and control infrastructure, to the use of private companies in foreign influence operations. The United States is responding to a reality—imperfectly, at real cost, and without always having the best alternatives in place. But it is responding to a reality.
The Challenge for Democracies: Acting Quickly Without Sacrificing Their Values
The greatest challenge for democracies in the face of the 1260H list and the technological competition it symbolizes is neither economic nor technological—it is political. How can they act with the speed and determination needed to challenge China’s technological rise without replicating the adversary’s authoritarian methods? How can national security be protected without sacrificing trade freedoms, the right to a fair trial, and transparency in designation criteria? How can alliance solidarity be maintained without demanding economic sacrifices from partners that their populations are not prepared to accept? There are no perfect answers to these questions. There are negotiated, imperfect, evolving answers—just like all policies in functioning democracies.
The 1260H list is an imperfect response to a real challenge. It deserves to be evaluated, adjusted, and publicly defended by those who implement it. Alibaba deserves a fair trial—and U.S. courts will provide one. WuXi AppTec deserves clear and defensible designation criteria—and public debate can refine them. But behind every court case, behind every lobbying decision, behind every list update, a strategic reality remains: in a world where technology has become the primary arena of power competition, inaction is also a choice—and it is a choice whose consequences will be paid for on the battlefields of the future.
The 1260H list currently has 188 names. It will have more tomorrow. And behind each name is a company navigating the demands of the Chinese government and the realities of the global market. It is this space of tension—between the logic of power and the logic of the market—that history is in the process of closing. For the better, I hope.
By Maxime Marquette, columnist
Sources
Primary sources
The Star — Tech giant Alibaba sues Pentagon over China military blacklist — June 26, 2026
Politico — K Street ditches Chinese clients as Pentagon ban takes effect — June 30, 2026
Ground News — China sanctions 10 U.S. defense firms in trade clash — June 22, 2026
Secondary Sources
19FortyFive — Analysis and implications of the list of Chinese military companies — June 2026
Foreign Policy — Expansion of the Pentagon’s 1260H list and the U.S.-China tech war — June 2026
Kyiv Independent — China-Russia technology partnership and dual-use risks — June 2026
This content was created with the help of AI.