In recent years, Chinese enterprises have repeatedly become the focus of US policy lists, with the situation escalating further since the beginning of 2025.

First, Tencent, alongside CATL and other enterprises, was included in the CMC list (Restricted Procurement List), sparking widespread concern and speculation.

Then, news emerged from overseas that Tencent, which had previously been deeply entangled in the "Notorious Markets List," had experienced a turnaround and been removed by the Office of the United States Trade Representative (USTR).

Amidst these listings and removals, some analysts have pointed out that the fluctuating attitudes towards Chinese enterprises, particularly Tencent, demonstrate a lack of systematic and unified action among various US government departments.

Behind this lies the US government's panic and anxiety regarding the rise of Chinese technology enterprises, coupled with the ambiguity and confusion in formulating these lists among various US government departments.

01 Fluctuating Lists: Inconsistent Approaches Among US Government Departments

On January 8, the USTR released the so-called "2024 Notorious Markets List for Counterfeiting and Piracy." Tencent WeChat was included in the list twice in 2022 and 2023 but was removed for the first time this year.

The US claims that the list aims to expose online and physical market actors allegedly contributing to large-scale piracy and trademark counterfeiting. Managed by the USTR, this list has long focused on intellectual property issues, blacklisting so-called market entities with infringement activities.

According to reports, Tencent strongly opposed its inclusion in the list and emphasized to the USTR that it has long been a global leader in supporting a robust intellectual property system, investing heavily in intellectual property, and collaborating globally to promote intellectual property protection.

Just a few days before this "turnaround," Tencent also "ran into trouble" alongside CATL and SenseTime.

On January 6, local time, the US Department of Defense included multiple Chinese companies, including Tencent, CATL, and SenseTime, in the CMC list (Chinese Military Companies List), causing an uproar in the industry.

The CMC list, also known as the "Section 1260H List," includes companies listed as Chinese military companies by the US Department of Defense based on Section 1260H of the National Defense Authorization Act for Fiscal Year 2021.

The alleged criteria include whether the company is directly or indirectly owned, controlled, or represented by the Chinese military, and whether it contributes to the civil-military integration of China's defense industrial base. However, these criteria are vague and arbitrary.

It's worth noting that this list is not a sanctions list but restricts procurement transactions between listed companies and the Department of Defense and its suppliers. In reality, these well-known Chinese companies do not typically conduct business with the US Department of Defense, so the direct and substantial impact is relatively small.

After being included in the CMC list, Tencent, CATL, and SenseTime all responded swiftly. Tencent stated that its inclusion was obviously a mistake, as it is not a military industrial enterprise or supplier, and the list has no direct impact on its existing business. Tencent vowed to actively work with relevant US departments to resolve misunderstandings.

SenseTime also issued a statement emphasizing that it focuses on empowering various industries with artificial intelligence technology and has never been involved in improper areas as referred to in the list. CATL responded that as a new energy power battery enterprise, its core business focuses on green energy innovation, and it does not engage in any military-related activities. Being listed without reason is regrettable.

The dynamic changes in these lists reflect the ongoing tug-of-war between Chinese and American enterprises. Every change affects the nerves of both sides and even the global industrial chain, but the complexity of these lists also leaves people feeling confused.

02 Unveiling the Lists: How Many Anti-China Lists Does the US Have?

In recent years, for political, economic, and other purposes, the US has frequently utilized various lists to target Chinese enterprises, attempting to curb China's development.

First is the well-known "Entity List," which is a US "export control list."

Simply put, after being included in this list, it becomes difficult for related enterprises to obtain products, software, and technology supplies from US enterprises from a supply chain perspective. From an international market expansion perspective, the opportunities for these enterprises to develop in the international market, especially to enter the US market, are limited. From an enterprise innovation perspective, they cannot integrate US innovation resources, including high-tech talents and products, thereby restricting their ability to obtain innovation resources from the US.

Huawei serves as a prime example. Under the ban, US enterprises ceased supplying key products and technologies to Huawei, jeopardizing its high-end chip supply for its mobile phone business and plunging it into difficulties. Despite Huawei's 5G technology leading the world, it has been boycotted by the US in collaboration with its allies. Many European and American operators have terminated cooperation, hindering Huawei's entry into the European and American 5G infrastructure markets, forcing it to focus on domestic development.

The CCMC, later developed into the NS-CMIC list, carries a strong sense of military sanctions. The CCMC is an early US sanctions list targeting China's military-related enterprises, designated by the US Secretary of Defense and the Office of Foreign Assets Control (OFAC) of the Treasury Department. In 2021, the NS-CMIC list replaced the CCMC, with designation authority transferred to the US Secretary of the Treasury, expanding designation criteria to include companies in the surveillance technology field, continuing to shackle the overseas financial and investment activities of relevant Chinese enterprises.

Xiaomi was once deeply entangled in this list. At that time, the US included Xiaomi on the list based on far-fetched grounds, such as Lei Jun receiving an honor from the Ministry of Industry and Information Technology and Xiaomi's 5G and AI investment plans involving so-called "technologies necessary for modern military operations," leading to the suspension of some Xiaomi projects. Later, through Xiaomi's efforts, a litigation settlement agreement was reached with the US government, and Xiaomi was removed from the US government's "blacklist."

The "Notorious Markets List," managed by the USTR and focusing on intellectual property issues, has degraded into a trade protection tool. In addition to Tencent WeChat, e-commerce platforms such as Alibaba and JD.com were also included and later regained their reputation by strengthening intellectual property protection.

There is also the CMC list, which includes Tencent and CATL. Established based on Section 1260H of the National Defense Authorization Act for Fiscal Year 2021, it adds relevant regulations such as "civil-military integration contributors" on top of the CCMC criteria.

The CMC list has a broader scope than the CCMC, but the CMC does not impose any direct restrictions on enterprises, and its substantive impact is limited. It is also expected to be lifted through litigation.

Moreover, there are the Unverified List (UVL), the Specially Designated Nationals (SDN) List, and others. These lists are numerous and complicated, with many having arbitrary standards and a lack of transparency in the formulation process, resulting in many enterprises being inexplicably "listed," disrupting the stability of the international economic and trade order.

03 How Effective Are These "Chaotic" Lists?

In today's globalized business battlefield, the US has transformed into a "list-making machine," with various lists targeting Chinese enterprises becoming a heavy "weapon" in Sino-US economic and trade frictions. However, their frequent changes resemble farces.

Currently, the US government is in a sensitive "transition period" between old and new powers, and various departments within the US are engaged in a "chaotic war" to compete for the right to speak on China policy. The Department of Commerce, the Department of Defense, the Treasury Department, the Office of the Trade Representative, and others have issued lists, but there is no unified planning.

The Department of Commerce's Entity List focuses on export controls, attempting to cut off US links in the global supply chains of relevant Chinese enterprises. The Department of Defense is keen on formulating various military-related lists, falsely accusing some Chinese enterprises under the guise of military security. The Treasury Department wields the big stick of financial sanctions, led by OFAC, to restrict fund transactions, hindering the overseas fund flow of enterprises. The Office of the Trade Representative specializes in the intellectual property field with the "Notorious Markets List," tarnishing the international reputation of Chinese enterprises.

The sanctions criteria of some departments often change arbitrarily and are vague, merely to highlight their "toughness" towards China during their term and "report" to specific domestic political forces.

This chaotic situation not only affects Chinese enterprises but also leaves US enterprises confused. Those US enterprises with in-depth industrial chain cooperation with China face frequent and uncertain list changes, leading to hesitation in investment decisions, uncertainty in supply plans, and disruption of normal business operations.

In contrast, China has accumulated significant experience in responding to this series of "list tactics" by the US, and its ability to respond has become increasingly proficient.

Faced with the Entity List dilemma, Huawei has demonstrated strong resilience, resolutely increasing investment in independent research and development. HiSilicon chips have continued to iterate and upgrade in a difficult environment, gradually breaking through performance bottlenecks from the Kirin series of chips to the emergence of the HarmonyOS operating system, building Huawei's own ecosystem, and achieving business diversification and transformation.

Faced with the "Notorious Markets List," many Chinese enterprises, including Tencent, have collectively strengthened intellectual property management.

Faced with the CMCC list, Xiaomi was removed through litigation. Similarly, facing the CMC list, companies such as AMEC, Hesai Technology, and IDG Capital have all been removed through litigation.

Nowadays, enterprises such as Tencent and CATL have also responded swiftly, immediately forming professional teams across multiple fields such as law, public relations, and technology, deeply studying the details of list rules, uncovering loopholes and unreasonableness, and preparing to seek justice in international courts through legal proceedings.

It can be foreseen that as Chinese enterprises continue to grow and strengthen, they will continue to make efforts in technological innovation, compliance management, and international image shaping. Coupled with the comprehensive policy support and diplomatic escort of the Chinese government, Chinese enterprises have become increasingly capable of responding to these issues in recent years.

In the future, these disorganized "list tactics" of the US will only increasingly expose its anxiety and unease about the rapid growth of China's scientific and technological strength.

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