How we trace a supplier's owners

Updated 2026-10-04

The directory answers one question for each of its 25 suppliers: is it, or could it be, a prohibited foreign entity? This page explains how: where the facts come from, how shares are added up, and what the method cannot see yet.

Every link has a source

Each fact in the directory is one sourced statement, such as "Company A owns 22.45% of Company B", with the document it came from and the exact words quoted. The sources, in order of preference:

• Annual reports. Hong Kong-listed companies publish English reports listing substantial shareholders. Shenzhen- and Shanghai-listed companies publish Chinese reports on CNINFO with their top ten shareholders and their actual controller (实际控制人).
• Audited financial statements, whose first note usually names the largest shareholder.
• US filings such as Schedule 13D and 13G, which anyone holding more than 5% of a US-listed company must file.
• GLEIF, the global register of legal entity identifiers, which records which company consolidates another in its accounts. It gives no percentage, so the directory shows these links as "consolidates" rather than a share.
• US government lists; see the restricted lists.

Facts are added through reviewed changes, so the history shows who added what and when. A fact that stops being true is given an end date rather than deleted, so an old screening can still be reproduced.

Shares multiply up a chain

Ownership is followed upward from the supplier, one owner at a time, until it reaches a person, a government or a company with no recorded owners. Along each chain the shares multiply, the same way the tax law attributes ownership through companies:

When one owner reaches the supplier along more than one chain, the chains are added together.

Which owners count

An owner is covered if it is on a restricted list, or if it is organized in, or a national of, a covered nation (CN, RU, IR, KP). Then the supplier is flagged if:

For the combined test, each chain is counted once, at its nearest covered owner. If a covered holding company owns 30% of a supplier and is itself owned by a covered government, the 30% is counted once, not twice.

Three outcomes

• Flagged At least one finding above applies.
• Open items Nothing is flagged, but something could not be checked: an owner whose share is not disclosed, or a supplier whose country is not recorded.
• No ties found Nothing in the sources checked. This is not a clean bill of health, only the absence of a finding.

Open questions you can switch

Some readings of the law are not settled. Each supplier page lets you answer these yes or no and see the result change. They start at yes, the stricter reading.

Does a Hong Kong person or company count as China?

Hong Kong is part of the PRC, but some US rules treat it separately. Applies to entities recorded with country HK, such as CATL's chairman Zeng Yuqun.

Is a "domestic natural person" in an A-share report a Chinese national?

Chinese annual reports class shareholders as 境内自然人 (domestic natural person) without stating nationality. These people are recorded as CN and tagged domestic-natural-person.

Does a China-organized subsidiary of a non-Chinese company count?

For example, Volkswagen (China) Investment, which holds 24.29% of Gotion. Such entities are recorded as CN and tagged foreign-parent.

What the method cannot see yet

• Contracts. The law also counts effective control through supply, operating and licensing agreements. Those are rarely public, so the directory does not test them.
• Debt. Few companies disclose who holds their loans and bonds, so the 15% debt test is usually blank.
• Nominee accounts. Shares held through clearing systems, such as Hong Kong's HKSCC, hide the real owners and are left out.
• Nationality. Chinese reports often call a shareholder a "domestic natural person" without stating nationality, one of the open questions above.
• The public-company rules. For listed companies the law counts only shareholders that must report their stakes. The directory does not yet apply that narrower count.
• Timing. Shareholdings are as of each report's date, usually the last year-end. The law tests status on the last day of the taxable year.

Each supplier page lists the evidence behind every finding, so any reader can check the source and the arithmetic.