What is the Entity List?
The Entity List is a U.S. Commerce Department list. It names foreign parties reasonably believed to be, or at significant risk of becoming, involved in activities contrary to U.S. national security or foreign policy. Exporters need a license to send them the items an entry names.
Also known as: BIS Entity List, U.S. Entity List
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How it works
The Bureau of Industry and Security (BIS) publishes the Entity List. BIS is the U.S. Commerce Department agency behind the Export Administration Regulations (EAR). The regulation that sets it up says the list identifies persons, and in some cases addresses. It says they are reasonably believed to be, or to pose a significant risk of becoming, involved in activities contrary to U.S. national security or foreign policy interests.
A listing is a license requirement, not an outright ban. Anyone exporting, reexporting or transferring the items named in an entry to a listed party needs a BIS license. With narrow exceptions, license exceptions are not available. Each entry states what is covered and how applications will be reviewed.
The End-User Review Committee generally makes decisions. Its members are the Commerce (chair), State, Defense and Energy departments and, where appropriate, the Treasury. Under BIS's rules, adding an entry takes a majority vote. Removing or changing one requires a unanimous vote.
Why it matters
The list has been used against Chinese technology companies. A rule effective May 16, 2019 added Huawei and 68 of its non-U.S. affiliates in 26 destinations. BIS cited reasonable cause to believe the company had been involved in activities contrary to U.S. national security or foreign policy. The rule required a license for all items subject to the EAR, with a presumption of denial.
Until late 2025, a listed company's legally distinct affiliates were not covered unless BIS listed them separately. An interim final rule was published on September 30, 2025. BIS calls it the Affiliates Rule. It applied the list's restrictions automatically to any entity at least 50 percent owned by one or more listed entities. BIS said the change addressed diversion concerns.
Where things stand in 2026
The Affiliates Rule is on hold. BIS stayed it from November 10, 2025 until November 9, 2026. It wrote the provisions to return on November 10, 2026 unless the suspension was extended. On September 23, 2026, Treasury Secretary Scott Bessent said a U.S.-China trade truce due to end on November 10 would run until January 10, 2027, NBC News reported. The trade publication Export Compliance Daily reported on September 25, citing a U.S. official, that the Affiliates Rule's effective date would move with it. As of October 6, 2026, the regulation text on BIS's website still showed the stay ending on November 9, 2026.
Sources
- 15 CFR § 744.16 - Entity List, Legal Information Institute, Cornell Law School
- Part 744 - Control Policy: End-user and End-use Based (Export Administration Regulations), Bureau of Industry and Security, U.S. Department of Commerce
- Addition of Entities to the Entity List, Federal Register (Bureau of Industry and Security)
- Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities, Federal Register (Bureau of Industry and Security)
- One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities, Federal Register (Bureau of Industry and Security)
- U.S. and China agree to extend trade truce through Jan. 10, Bessent says, NBC News
- US-China Trade Truce, Including BIS Affiliates Rule, Extended 2 Months, US Says, Export Compliance Daily
