I. US Steps Up Suppression: 23 Chinese Entities Added to Entity List, 13 in Semiconductor & IC Sector

On September 12 (local time), the US Department of Commerce’s Bureau of Industry and Security (BIS) issued an announcement, adding 23 Chinese entities to the Entity List, claiming they “undermine US national security or foreign policy interests”. Among them, over half (13) are semiconductor and integrated circuit (IC)-related enterprises. The specific list is as follows:

Specific List of 23 Newly Added Chinese Entities

1. Semiconductor & IC-Related Enterprises (13)

1. Beijing Fudan Microelectronics Technology Co., Ltd.
2. Shanghai Fudan Microelectronics Co., Ltd.
3. Shanghai Fudan Microelectronics (HK) Co., Ltd.
4. Shenzhen Fudan Microelectronics Co., Ltd.
5. Shanghai Fukong Hualong Microsystem Technology Co., Ltd.
6. Shanghai Fuwei Xunjie Digital Technology Co., Ltd.
7. Sino IC Technology Co., Ltd.
8. GMC Semiconductor Technology (Wuxi) Co., Ltd.
9. Jicun Semiconductor Technology (Shanghai) Co., Ltd.
10. Changsha NetForward Electronic Technology Co., Ltd.
11. Changzhou NetForward Microelectronics Co., Ltd.
12. Chengdu NetForward Microelectronics Co., Ltd.
13. Shenzhen NetForward Microelectronics Co., Ltd.

2. Biotechnology & Life Sciences Enterprises (3)

1. Beijing Tianyi Huiyuan Biotechnology Co., Ltd.
2. Beijing Tsingke Biotech Co., Ltd.
3. Sangon Biotech (Shanghai) Co., Ltd.

3. Research Institutes for Aerospace Remote Sensing, Quantum & Timing Systems (2)

1. Aerospace Information Research Institute, Chinese Academy of Sciences
2. National Time Service Center, Chinese Academy of Sciences

4. Industrial Software/Engineering Software Enterprises (2)

1. Hong Kong DEMX Co., Ltd.
2. Shanghai Suochen Information Technology Co., Ltd.

5. Supply Chain & Logistics Service Enterprises (3)

1. Hua Ke Logistics (HK) Limited
2. Hua Ke Supply Chain (HK) Limited
3. Shenzhen Xinlikang Supply Chain Management Co., Limited

In response, China firmly opposes the US move:

• The Ministry of Commerce condemned the US for “overgeneralizing national security and abusing export controls”, noting that this act disrupts global industrial and supply chains, harms the legitimate rights and interests of enterprises, and is not conducive to dialogue and cooperation;
• Foreign Ministry Spokesperson Guo Jiakun denounced it as a “hegemonic act” that violates international law, urging the US to stop politicizing economic, trade and technological issues. China will take necessary measures to safeguard the legitimate rights and interests of Chinese enterprises.

II. China’s Countermeasure 1: Launch of Anti-Dumping Investigation on US-Origin Analog ICs from Sept 13

In response to US suppression, the Ministry of Commerce launched an anti-dumping investigation into imported analog ICs originating from the US starting September 13:

• Background: On July 23, the Ministry received an application from the Jiangsu Semiconductor Industry Association, and the applicant meets the statutory qualification requirements;
• Key Evidence: From 2022 to 2024, the import volume of US-origin analog ICs increased by 37% cumulatively, while the import price dropped by 52% cumulatively, suppressing domestic product prices and harming the domestic industry;
• Scope of Investigation: General interface ICs (CAN, RS485, I2C, digital isolators, etc.) and gate driver ICs (low-side, half-bridge/multi-channel, isolated types) using processes of 40nm and above, classified under HS Code 85423990 (excluding other products under this HS code);
• Investigation Period: The dumping investigation period is January-December 2024, and the industrial injury investigation period is January 2022-December 2024. The investigation will be conducted in accordance with the law to protect the rights of all stakeholders.

III. China’s Countermeasure 2: Simultaneous Launch of Anti-Discrimination Investigation on US Measures in IC Sector Against China

On September 13, the Ministry of Commerce simultaneously issued an announcement, launching an anti-discrimination investigation into US discriminatory measures in the IC sector against China:

• Legal Basis: In accordance with the “Foreign Trade Law of the People’s Republic of China”, targeting the US “discriminatory prohibitions, restrictions or similar trade measures”;
• Objects of Investigation: US Section 301 tariffs on China since 2018, export controls (restrictions on ICs, equipment, and “US persons” participating in Chinese semiconductor projects) since 2022, restrictions under the “CHIPS and Science Act”, and the US restriction on Huawei Ascend chips in May 2025;
• Investigation Period: Starting September 13, the investigation period is usually 3 months, and may be appropriately extended under special circumstances;
• Procedures: The investigation will be conducted through questionnaires, hearings, etc. Stakeholders may submit comments or apply for hearings within the specified time limit.

Core Summary

This week, tensions in the China-US semiconductor sector escalated significantly: The US targeted Chinese IC enterprises in the name of “national security”, while also affecting the biotechnology, aerospace, software, and supply chain sectors. In response, China launched dual investigations (anti-dumping + anti-discrimination) to safeguard the legitimate rights and interests of the domestic industry in accordance with the law, countering US unilateral sanctions and demonstrating its determination to protect the stability of global industrial and supply chains.