Who will be removed from Chinese Military Companies list by June 30, 2027?
I think Alibaba is more likely than not to remain on the 1260H list through June 30, 2027. The lawsuit and temporary court relief create some upside for delisting, but the current official posture still points to continued designation.
Analysis
The strongest anchor point is that Alibaba is currently on the official June 8, 2026 Section 1260H list. The DoD release says it updated the list to 188 entities and that it will keep updating it as appropriate, while the new Section 805 guidance makes clear that the related indirect supply-chain prohibition reaches June 30, 2027. That means any Yes outcome requires a later affirmative delisting step, not just a pause in enforcement.
The main pro-Yes development is the legal challenge. Alibaba sued the U.S. government on June 23, 2026, and a federal judge later ordered the Pentagon not to enforce the new lobbying restriction against Alibaba while the challenge is reviewed. But that order was expressly narrow and not a final ruling on the merits or on Alibaba’s inclusion on the 1260H list, so it is better read as procedural relief than as a sign that delisting is imminent.
Historically, DoD can remove companies from the 1260H list, so the market is not relying on a fictional mechanism. The problem for Yes is that removals appear uncommon relative to the list’s size, and the most recent official 1260H-related release index I found still points to the June 8, 2026 update rather than any later Alibaba delisting. Taken together, I think the market is giving too much credit to legal noise and not enough weight to how deliberate and politically sensitive an actual removal would be.
Arguments
For
- Arguments for Yes: Alibaba has already filed a federal lawsuit seeking removal, so a favorable ruling could directly lead to delisting.
- Arguments for Yes: DoD has shown it can remove entities from the list when its current assessment changes, proving that delisting is administratively possible.
- Arguments for Yes: The temporary court relief suggests at least some judicial openness to Alibaba’s challenge, which keeps the door open to a broader win later.
Against
- Arguments against Yes: The June 8, 2026 DoD update freshly reaffirmed Alibaba’s inclusion on the official 1260H list.
- Arguments against Yes: The court order so far is limited to the lobbying restriction and explicitly does not remove Alibaba from the list.
- Arguments against Yes: The government’s latest official posture is continued enforcement, including a supply-chain ban timeline that extends into 2027.
Key drivers
- The current official status is still listed, so a Yes outcome needs an additional affirmative DoD delisting action.
- Alibaba’s pending lawsuit creates a real but uncertain pathway to removal if the court goes beyond temporary relief.
- The June 30, 2027 supply-chain prohibition keeps the policy pressure high and makes the designation strategically important.
- Prior removals show the agency can delist companies, but those actions appear to be exceptions rather than the rule.
Risk factors
- The temporary injunction may expire or remain limited, leaving the official list unchanged through the deadline.
- DoD can simply maintain the designation until June 30, 2027 even if litigation continues.
- A partial settlement or procedural accommodation would not qualify unless Alibaba is actually removed from the list.
- The latest official signals show continued expansion and enforcement of the 1260H framework, not retrenchment.
Scenarios
Best case
Alibaba wins meaningful relief in court or DoD re-evaluates the designation, and a subsequent official notice removes it from the 1260H list before June 30, 2027.
Most likely
Alibaba keeps litigating and may preserve some limited procedural breathing room, but the official 1260H list still includes it at the resolution date.
Worst case
The lawsuit only produces temporary or narrow enforcement relief, the official list never changes, and Alibaba remains designated through June 30, 2027.
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