365 Days of Claims
Claim #213 of 365
Mostly True but Misleading high confidence

The stated fact is accurate, but presenting it as a "win" obscures significant harm or context.

export-controlschinaentity-listIP-theftmilitary-modernizationmischaracterizationcontinuationattribution-problem

The Claim

Blacklisted dozens of Chinese companies in a bid to reduce the Chinese Communist Party’s intellectual property theft.

The Claim, Unpacked

What is literally being asserted?

Two factual components: (1) the administration placed “dozens” of Chinese companies on a blacklist, and (2) the purpose was to “reduce the Chinese Communist Party’s intellectual property theft.” The term “blacklisted” in this context refers to the Bureau of Industry and Security’s Entity List, which restricts exports of U.S.-origin technology to designated entities.

What is being implied but not asserted?

That the Entity List additions were driven by, and targeted at, intellectual property theft specifically. That the blacklistings represent a novel, aggressive response to Chinese IP theft. That these actions are meaningfully reducing IP theft. That this is a Trump administration initiative rather than a bipartisan, multi-administration escalation.

What is conspicuously absent?

That the stated justifications for the actual Entity List additions in 2025 were overwhelmingly about military modernization, not intellectual property theft — two-thirds of the 95 Chinese entities added cited military modernization (hypersonic missiles, quantum technology, AI, supercomputing). That the Biden administration added far more Chinese entities — 412 in total versus Trump’s first-term 259, with Biden adding 140 in December 2024 alone. That the Trump administration simultaneously loosened export controls in other ways: shifting Nvidia H200 and AMD MI308 chip export review from “presumption of denial” to “case-by-case,” rescinding the Biden-era AI Diffusion Rule, and suspending the Affiliates Rule as a concession to China in the November 2025 trade deal. That the Entity List, while a legitimate national security tool, has limited documented effectiveness at reducing IP theft — which the USTR’s own 2025 report acknowledges is ongoing and worsening in some dimensions.

Evidence Assessment

Established Facts

The Trump administration added 95 Chinese entities to the BIS Entity List in 2025 — “dozens” is numerically accurate. According to CNAS’s “Sanctions by the Numbers: 2025 Year in Review,” the second Trump administration added 95 Chinese persons to the Entity List across four major actions: the March 2025 batch (53 Chinese entities across two Final Rules), the September 2025 batch (23 Chinese entities), and the October 2025 batch (19 Chinese entities). “Dozens” is technically correct — 95 is nearly eight dozen. 1

The stated justifications for these additions were overwhelmingly military modernization, not intellectual property theft. CNAS reports that “roughly two-thirds” of the 95 Chinese additions were “persons involved in researching, producing, or illicitly acquiring goods and technologies in support of the PRC’s military modernization efforts, particularly its hypersonic missile program and capabilities in quantum, AI, semiconductors, and supercomputing.” The March 2025 BIS press release cited “military modernization,” “supercomputer development,” and “quantum technology” — not IP theft. The September 2025 additions cited military modernization and diversion to SMIC and Russia. The October 2025 additions cited supplying Iran with drone components. Across all four 2025 Entity List actions, intellectual property theft was not cited as a primary justification in any Federal Register notice. 2

The Trump administration’s 2025 Entity List pace was dramatically slower than the Biden administration’s. CNAS data shows Trump added 143 total entities to the Entity List in 2025 (95 Chinese), compared to an annual average of 507 entities from 2022-2024 under Biden. The Biden administration added 412 Chinese entities total (versus Trump first term’s 259), including 140 Chinese semiconductor firms in a single action in December 2024. By end of 2024, the Entity List included over 1,000 Chinese individuals and entities, with 250+ added in 2024 alone — the highest annual increment in a decade. 3

The Trump administration simultaneously loosened export controls on advanced chip exports to China. As documented in Item 116, the administration shifted license review for Nvidia H200 and AMD MI308 chip exports to China from “presumption of denial” to “case-by-case” review, approved those chips for China sale with a 15% revenue share requirement, and rescinded the Biden-era AI Diffusion Rule. In November 2025, as part of the U.S.-China trade deal, BIS suspended the Affiliates Rule (the “50 percent rule”) for one year — effectively exempting subsidiaries and affiliates of Entity List companies from export restrictions. BIS also removed Arrow China Electronics Trade Co. from the Entity List. These actions represent a net loosening of the export control posture toward China. 4

Chinese IP theft remains a massive, ongoing problem that Entity List additions have not measurably reduced. The USTR’s 2025 National Trade Estimate Report — published under the Trump administration on March 31, 2025 — devoted 47 pages to China, noting that “actors affiliated with the Chinese Government and the Chinese military have infiltrated the computer systems of U.S. companies, stealing terabytes of data.” The FBI estimates Chinese operations account for 50-80% of all economic espionage cases. Congressional estimates place the cost at $225-600 billion annually. The USTR’s own Section 301 four-year review (May 2024) found that “despite some positive developments, China persists in efforts to transfer technology from U.S. companies and the burden of China’s technology transfer-related acts, policies, and practices on U.S. commerce has increased.” 5

Strong Inferences

The claim’s framing of “intellectual property theft” as the motivation mischaracterizes the actual policy rationale. The Entity List is a national security and foreign policy tool, not an intellectual property enforcement mechanism. Its primary legal basis under the Export Administration Regulations (EAR) is restricting exports that could contribute to activities contrary to U.S. national security or foreign policy interests. While IP theft and military modernization overlap — stolen technology can accelerate weapons development — the specific justifications in the 2025 Federal Register notices centered on military modernization, proliferation, and technology diversion, not IP theft per se. Placing the claim under “Forging a Stronger, Modernized Military Force” while framing it as reducing “intellectual property theft” conflates two distinct policy objectives in a way that overstates the scope of what was done. 6

Entity List additions, while legitimate, have limited effectiveness as an IP theft countermeasure. The Entity List restricts what U.S. companies can export to listed entities — it does not address the primary mechanisms of Chinese IP theft, which include cyber intrusions, insider recruitment, talent programs, and forced technology transfer as a condition of market access. A 2024 USTR review concluded that Chinese technology transfer practices had actually worsened despite years of escalating Entity List additions and export controls. The Entity List is better understood as a military technology denial tool than an IP theft reduction tool. 7

The Entity List expansion represents bipartisan policy continuity, not a distinctive Trump initiative. Both the Trump first term (259 Chinese entities), Biden administration (412 Chinese entities), and Trump second term (95 Chinese entities in 2025) have steadily expanded the Entity List. The Trump second term pace is actually the slowest of the three. The claim presents this as a Trump initiative, but the policy architecture, legal framework, and escalation trajectory predate Trump’s second term and will likely continue regardless of which party holds the presidency. 8

What the Evidence Shows

The factual core is defensible: the Trump administration did add dozens of Chinese companies to the Entity List in 2025. The number — 95 Chinese entities — comfortably exceeds “dozens.” These are real policy actions with real consequences for the listed companies, which now face significant barriers to accessing U.S.-origin technology.

But the claim’s framing is misleading in three important ways. First, it mischaracterizes the motivation: the actual Entity List additions in 2025 were justified by military modernization concerns — hypersonic missiles, quantum computing, AI, supercomputing, and drone proliferation to Iran — not intellectual property theft. IP theft is real and serious, but it is not what these specific blacklistings were about. Second, it implies this is a novel Trump initiative when it is actually a bipartisan policy that has escalated across three administrations, with the Trump second term actually adding entities at a dramatically slower pace than Biden (95 Chinese entities in 2025 versus an average of 507 total entities annually from 2022-2024). Third, it omits that the administration simultaneously loosened export controls in significant ways — approving advanced chip sales to China, rescinding the AI Diffusion Rule, and suspending the Affiliates Rule as a trade concession.

The most telling contradiction is the claim’s placement under “Forging a Stronger, Modernized Military Force” while being framed as reducing “intellectual property theft.” The actual Entity List additions were about denying China military-applicable technology — which is a military force readiness rationale, not an IP theft rationale. The administration chose to frame a military technology denial policy as an IP theft reduction policy, perhaps because “reducing IP theft” sounds more consumer-friendly than “restricting China’s access to supercomputing components.”

There is also the question of whether Entity List additions actually reduce IP theft, and the evidence is discouraging. The USTR’s own reviews have found that Chinese technology transfer practices worsened even as the Entity List grew from hundreds to over 1,000 Chinese entries. The Entity List controls what American companies can sell abroad; it does not address cyber espionage, insider theft, or forced technology transfer — the primary channels of Chinese IP acquisition.

The Bottom Line

Steel-manning: the administration genuinely added 95 Chinese entities to the Entity List in 2025, and these are consequential actions. Being placed on the Entity List materially restricts a company’s ability to acquire U.S.-origin technology, which serves genuine national security interests. Some of these additions closed real loopholes — particularly the six Inspur subsidiaries that had been operating freely despite their parent’s listing since 2023. China’s military modernization is a legitimate threat, and restricting technology flows to support it is sound policy.

But calling these additions “a bid to reduce the Chinese Communist Party’s intellectual property theft” mischaracterizes what happened. The actions were justified by military modernization and proliferation concerns, not IP theft. The pace was slower than Biden’s. The administration simultaneously loosened controls in other dimensions. And the Entity List, while useful for technology denial, has not demonstrably reduced Chinese IP theft, which the administration’s own USTR report acknowledges is ongoing and in some respects worsening. The claim takes a real, moderate-scale continuation of bipartisan policy and repackages it with a different, more appealing rationale than the one actually used.

Sources

Footnotes

  1. CNAS, “Sanctions by the Numbers: 2025 Year in Review.” Trump second administration added 95 Chinese persons to Entity List in 2025. Thompson Hine SmarTrade: March 2025 additions added 53 Chinese entities across two Final Rules; September 2025 added 23 Chinese entities; October 2025 added 19 Chinese entities. https://www.cnas.org/publications/reports/sanctions-by-the-numbers-2025-year-in-review; https://www.thompsonhinesmartrade.com/2025/03/bis-adds-over-80-companies-to-entity-list-with-heavy-focus-on-china/; https://www.cmtradelaw.com/2025/09/bis-announces-addition-of-32-entities-to-the-entity-list-including-for-exports-to-russia/; https://www.internationaltradeinsights.com/2025/10/bis-adds-29-entities-and-addresses-in-china-turkey-and-the-uae-to-entity-list/ ↩

  2. CNAS, “Sanctions by the Numbers: 2025 Year in Review”: “roughly two-thirds were persons involved in researching, producing, or illicitly acquiring goods and technologies in support of the PRC’s military modernization efforts.” March 2025 BIS additions cited military modernization, supercomputer development, quantum technology. September 2025 cited military modernization and diversion to SMIC. October 2025 cited supplying Iran with drone components. IP theft not cited as primary justification in any 2025 Federal Register notice. https://www.cnas.org/publications/reports/sanctions-by-the-numbers-2025-year-in-review; https://www.thompsonhinesmartrade.com/2025/03/bis-adds-over-80-companies-to-entity-list-with-heavy-focus-on-china/; https://www.cmtradelaw.com/2025/09/bis-announces-addition-of-32-entities-to-the-entity-list-including-for-exports-to-russia/ ↩

  3. CNAS, “Sanctions by the Numbers: Comparing the Trump and Biden Administrations’ Sanctions and Export Controls on China.” Trump first term: 259 Chinese entities. Biden: 412 Chinese entities. Trump 2025: 143 total entities added (95 Chinese), versus Biden-era annual average of 507. Fortune/TechNode: Biden added 140 Chinese semiconductor firms in December 2024 alone. AlixPartners 2024 review: Entity List grew to over 1,000 Chinese entries with 250+ added in 2024. https://www.cnas.org/publications/reports/sanctions-by-the-numbers-comparing-the-trump-and-biden-administrations-sanctions-and-export-controls-on-china; https://technode.com/2024/12/03/us-adds-140-chinese-semiconductor-firms-to-entity-list-targeting-key-equipment-makers/ ↩

  4. CRS Report R48642 (per Item 116 analysis): Trump shifted license review from “presumption of denial” to “case-by-case.” BIS approved Nvidia H20 and AMD MI308 for China sale. Biden-era AI Diffusion Rule rescinded. Skadden: BIS suspended Affiliates Rule (50% ownership rule) for one year starting November 10, 2025, as part of U.S.-China trade deal. Arnold & Porter: BIS removed Arrow China Electronics Trade Co. from Entity List in November 2025. https://www.congress.gov/crs-product/R48642; https://www.skadden.com/insights/publications/2025/11/bis-suspends-affiliates-rule-for-one-year-as-part-of-the-us-china-trade-deal; https://www.arnoldporter.com/en/perspectives/blogs/enforcement-edge/2025/11/doc-suspends-enforcement-of-the-affiliates-rule-for-one-year ↩

  5. USTR, 2025 National Trade Estimate Report on Foreign Trade Barriers, March 31, 2025. China section (47 pages) notes cyber infiltration, large-scale online piracy, widespread counterfeiting. FBI: Chinese operations account for 50-80% of economic espionage cases. Congressional estimates: $225-600 billion annual cost. USTR Section 301 four-year review (May 2024): “despite some positive developments, China persists in efforts to transfer technology from U.S. companies and the burden of China’s technology transfer-related acts, policies, and practices on U.S. commerce has increased.” https://www.chinaiplawupdate.com/2025/04/united-states-trade-representative-2025-national-trade-estimate-report-on-foreign-trade-barriers-china-needs-to-increase-damages-and-criminal-penalties-for-ip-infringement/; https://ustr.gov/sites/default/files/05.14.2024%20Four%20Year%20Review%20of%20China%20Tech%20Transfer%20Section%20301%20(Final).pdf ↩

  6. Entity List legal authority under Export Administration Regulations (15 C.F.R. Part 744). Entities added when there is “reasonable cause to believe” involvement in activities “contrary to the national security or foreign policy interests of the United States.” March 2025 Federal Register notices (90 FR 2025-05426, 90 FR 2025-05427) cite military modernization and supercomputing, not IP theft. The Register: additions targeted “subsidiary structures” and “military end use,” not IP violations. https://www.federalregister.gov/documents/2025/03/28/2025-05427/additions-to-the-entity-list; https://www.theregister.com/2025/03/26/us_entity_list_subsidiaries/ ↩

  7. USTR Section 301 four-year review (May 2024): Chinese technology transfer practices worsened despite escalating export controls. Entity List restricts U.S. exports but does not address cyber intrusions, insider recruitment, talent programs, or forced technology transfer. CSIS: no comprehensive short-term solution because “IP theft is systemic.” Stanford Law School: Entity List provisions “entail no punishment for American violators or foreign beneficiaries.” https://ustr.gov/sites/default/files/05.14.2024%20Four%20Year%20Review%20of%20China%20Tech%20Transfer%20Section%20301%20(Final).pdf; https://law.stanford.edu/2018/04/10/intellectual-property-china-china-stealing-american-ip/ ↩

  8. CNAS data: Trump first term 259 Chinese entities, Biden 412 Chinese entities, Trump second term 95 Chinese entities (2025). Bipartisan escalation pattern: “an effort that has grown more insistent with each administration.” Entity List existed since 1997; first major China-focused expansion under Obama. https://www.cnas.org/publications/reports/sanctions-by-the-numbers-comparing-the-trump-and-biden-administrations-sanctions-and-export-controls-on-china; https://www.cnas.org/publications/reports/sanctions-by-the-numbers-2025-year-in-review ↩