The US restricted lists that matter for batteries

Updated 2026-10-04

Several US government lists decide, or hint at, whether a battery supplier is a prohibited foreign entity. Some are written into the tax law by name; others are only warning signs. Here is what each one is, who keeps it, and how the directory uses it.

The lists

ListKept byMakes a company a specified foreign entity?Entries we hold
OFAC Specially Designated Nationals (SDN)
People and companies whose US assets are blocked. US persons are generally barred from dealing with them.
Treasury, Office of Foreign Assets Control Yes, through the CHIPS Act definition of a foreign entity of concern 11,918
Section 1260H Chinese military companies
Companies the Pentagon finds are Chinese military companies operating in the US, with named subsidiaries. Updated at least once a year.
Defense Department, in the Federal Register Yes, by name 188
UFLPA Entity List
Companies tied to forced labor in Xinjiang. Goods they make are presumed barred from US import.
Homeland Security, Forced Labor Enforcement Task Force Yes, by name 187
Section 154(b) battery makers
Six named battery makers: CATL, BYD, Envision Energy, EVE Energy, Gotion High-tech and Hithium, plus successors. The Pentagon may not buy their batteries from October 1, 2027.
Congress, in the FY2024 defense authorization act Yes, by name 6
BIS Entity List
Foreign parties that need a license to receive US exports, often for national security reasons.
Commerce, Bureau of Industry and Security No; a warning sign 3,419
BIS Military End-User List
Foreign military end users that need a license for certain US exports.
Commerce, Bureau of Industry and Security No; a warning sign 70
Chinese Military-Industrial Complex (NS-CMIC) list
Chinese companies whose publicly traded securities US persons may not buy.
Treasury, Office of Foreign Assets Control No; a warning sign 68

Entry counts are from the copies the directory screened against: companies only, people left out, and a parent and each named subsidiary counted separately.

Written into the law, or a warning sign

The tax law's definition of a specified foreign entity names four sources: the CHIPS Act's foreign entities of concern (which include the SDN list), the 1260H list, the UFLPA Entity List and the section 154(b) battery makers.1 A company on any of them is a specified foreign entity, and a company that one of them owns 25% of is a foreign-influenced entity.

The BIS Entity List, the Military End-User List and the CMIC list are not part of that definition. They still say something about a supplier: export controls and investment bans often follow the same ties the tax law cares about. The directory checks them as warning signs. The bottom of each supplier page names every list its screening used.

Where the data comes from

All but the last are refreshed monthly. A change that matches a supplier or owner is reviewed before it reaches the directory.

How names are matched

A list names specific legal entities, and a wrong match would flag an innocent supplier. So the directory matches only exact names or recorded aliases, after removing punctuation and legal suffixes such as "Co., Ltd.". Short acronyms must match on country too: "AESC" is also an alternate name of an unrelated Russian aviation company on the SDN list. It checks every owner in a supplier's chain, not just the supplier, because a listed owner can make the supplier a foreign-influenced entity.

Sources

  1. 26 U.S.C. 7701(a)(51)(B), specified foreign entity (Cornell LII).
  2. 15 U.S.C. 4651(8), foreign entity of concern.
  3. Public Law 118-31, section 154, prohibition on procurement of certain batteries.