Will CATL be removed from Chinese Military Companies list by June 30, 2027?

- [2026-06-08] The Department of War published the updated 1260H list. CATL remains on it. The list has 188 entities and adds 65. It also removes 10 entities that do not operate in the US, mostly CNOOC and COSCO subsidiaries, whose parents stay listed. The DoW release says it "will update the list with additional entities as appropriate". https://www.militaryspot.com/news/dow-releases-list-of-chinese-military-companies-in-u-s ; https://www.dentons.com/en/insights/alerts/2026/june/18/dod-expands-section-1260h-chinese-military-companies-list - [2026-06-08, reported 2026-06-15] Sayari's analysis of the June list names CATL among the primary designees still listed. https://sayari.com/resources/blog/1260h-list-update/ - [2026-06-12] CATL said it has already filed an administrative reconsideration request with the US government and will pursue removal. It was responding to a 21 May 2026 House Select Committee report that treated its silence on the listing as a default admission. This is a trade-site report of a company statement. https://www.evlithium.com/lifepo4-battery-news/catl-responds-us-congress-report-may2026.html - [2026-04, Bloomberg via TT, ~183 days before the fetch date] Bloomberg reported that CATL co-founder Pan led the removal campaign and met US officials in March 2025 and again in September. People familiar with the effort said Pan feared the chances of removal were slim. CATL still said it was "exploring legally available options". https://www.ttnews.com/articles/catl-pentagon-china-blacklist - [2025-01-07] CATL was first listed, and it has stayed listed through two list publications. https://www.federalregister.gov/documents/2025/01/07/2025-00070/notice-of-availability-of-designation-of-chinese-military-companies - [2026-08-07 to 08-18] Courts have ruled on other listed firms. WuXi AppTec won a preliminary injunction on 7 Aug that suspends enforcement of its designation. The D.C. Circuit remanded DJI's case on 14 Aug and Hesai's on 18 Aug, on due-process grounds. The Hesai court declined to vacate the designation, and the rulings did not order removal. Per the same source, the Pentagon must now give notice and a chance to respond before any new final decision. An injunction suspends enforcement but does not remove a name from the list, which this market does not count. https://finance.biggo.com/news/706fd74c-a06f-4163-93d9-d6617685b429 - [2026-08-28] CXMT sued the Pentagon over its listing. Quectel sued on 2026-05-11 and Alibaba on about 2026-06-24. I found no report of a CATL lawsuit. https://www.forth.news/articles/CeW5y1LdH2t7v41VqsS8Q ; https://www.quectel.com/news-and-pr/challenging-wrongful-section-1260h-designation/ - [2026-06-30] The DoD procurement ban on 1260H-listed entities took effect. Wider third-party prohibitions follow in June 2027. https://www.mofo.com/resources/insights/260626-dod-expands-the-section-1260h-chinese-military-companies-list - [2026-02 and 2026-04-29] The Pentagon twice published and then withdrew an expanded list without explanation, once in February 2026 and once in April 2026. Updates are therefore irregular. The list was published in Jan 2024, Jan 2025 and June 2026. Section 1260H requires at least annual updates, so the next is statutorily due by about June 2027. https://www.wilmerhale.com/en/insights/client-alerts/20260611-pentagon-adds-65-new-entities-to-the-1260h-list-of-chinese-military-companies ; https://thefederalnewswire.com/u-s-defense-department-drops-filing-that-would-expand-section-1260h-list-of-chinese-firms - [2026-10-16] Congressional hostility continues. Republicans' 14 Oct letter on COSCO cites its 1260H listing. I found nothing in the last 14 days on a CATL removal, a delisting notice or a CATL court filing. https://donaldjtrumppolls.com/republicans-demand-ccp-owned-shipping-giant-be-stripped-of-us-port-privileges/ - [Precedent] Removals have happened. Six entities came off in Jan 2025, and AMEC was removed in Dec 2024 after it sued. Hesai was removed in Aug 2024 and re-added in Oct 2024. The June 2026 removals were of subsidiaries that lack a US nexus. No major parent with strong congressional opposition has been delisted that I found. https://ishanvnagpal.substack.com/p/navigating-risks-with-1260h-listed BOTTOM LINE: As of 2026-10-16, CATL is still on the June 8, 2026 list. It has a pending administrative reconsideration request but no known lawsuit, and nothing suggests an imminent delisting. The likeliest route to removal before 30 June 2027 is the next annual list update, about June 2027, or a Pentagon reconsideration decision. Recent court rulings give procedural leverage to firms that sue, not to CATL directly. NOT FOUND: Any CATL lawsuit against the Pentagon. Any DoD response to CATL's reconsideration request. Any announced date for the next list update. Any delisting notice for CATL. I could not fetch the war.gov release page directly. I confirmed the June 8 list contents through secondary and law-firm sources, not the primary page.

- [2026-06-08] The Pentagon's June 8 update kept CATL on the list. It added 65 entities and removed 10, and CATL was not among the removals. The 10 removed were CNOOC, COSCO-finance and small-entity listings, each removed for having no US operations. Source: https://www.wilmerhale.com/en/insights/client-alerts/20260611-pentagon-adds-65-new-entities-to-the-1260h-list-of-chinese-military-companies - [2026-06-08] The list now has 188 entities. It is required annually through 2030, and the Pentagon had published nothing since January 2025. A February 2026 version was published and withdrawn within an hour, with no explanation. The next routine update would likely come around mid-2027 or later, so a CATL removal inside the window would probably need an ad hoc delisting. Source: https://www.clearytradewatch.com/2026/06/department-of-defense-adds-major-technology-automotive-and-biotechnology-firms-to-1260h-chinese-military-companies-list/ - [2026-04-15] Bloomberg reports that CATL co-chair Pan Jian lobbied Pentagon officials in March 2025 and again in September 2025, and CATL was still listed. Pan reportedly concluded the chances of removal were slim. The report says the main route off the list has been proving no US operations, which conflicts with CATL's US ambitions. CATL says it is "exploring legally available options". Source: https://www.ttnews.com/articles/catl-pentagon-china-blacklist - [2026-04-15] Bloomberg also notes that lawsuits by other companies seeking removal had mostly failed. The Pentagon has had little trouble justifying listings under the broad military-civil fusion criteria. Source: https://www.ttnews.com/articles/catl-pentagon-china-blacklist - [Historical base rate] Removals have been rare, and the main routes were these: - Xiaomi and Luokung were delisted in 2021 after winning court injunctions (under the earlier CCMC list). - Hesai was delisted in Oct 2024 and relisted on new grounds at the same time. - AMEC was removed in Dec 2024 after a court challenge. - About 3 firms were removed in the Jan 2024 update for lack of a US nexus or ownership changes. - 10 firms were removed in June 2026 for lack of a US nexus. Sources: https://ishanvnagpal.substack.com/p/navigating-risks-with-1260h-listed and https://www.govinfo.gov/content/pkg/FR-2024-10-29/pdf/2024-25168.pdf - [2026-08-18] The D.C. Circuit remanded Hesai's case on due-process grounds but did not vacate the designation. It had earlier remanded DJI's case (Aug 14), and WuXi AppTec obtained a preliminary injunction (Aug 7) that suspended the designation's effect. A suspension does not count as removal under this market's rules. Courts have so far produced procedural remands rather than delistings. Source: https://finance.biggo.com/news/706fd74c-a06f-4163-93d9-d6617685b429 - [2026-08] Commentators note that even if DJI wins on its 2025 designation, the June 2026 relisting under the amended criteria could keep it on the list. This suggests litigation wins are weak routes to full removal. Source: https://chinatechbite.substack.com/p/dji-grabs-narrow-us-court-victory - [2025-01-07] CATL was added in the Jan 2025 update. The same update created a formal reconsideration process, and FY25 NDAA §1346 requires written justification for additions and removals. CATL and Tencent said they would seek removal. Over 17 months later CATL was still listed. Sources: https://www.crowell.com/en/insights/client-alerts/new-year-updated-list-the-us-department-of-defense-updates-its-list-of-chinese-military-companies-with-ancillary-supply-chain-and-usg-contracting-impacts and https://www.federalregister.gov/documents/2025/01/07/2025-00070/notice-of-availability-of-designation-of-chinese-military-companies - [2026-06-12] The June list followed the Trump–Xi Beijing summit by a few weeks, and the Pentagon still expanded the list. Congressional China hawks (e.g., Moolenaar) press for more additions. Statutory bans on CATL's batteries (the FY24 NDAA ban on DoD procurement of CATL batteries, starting in 2027) apply separately from the 1260H listing. Sources: https://www.wilmerhale.com/en/insights/client-alerts/20260611-pentagon-adds-65-new-entities-to-the-1260h-list-of-chinese-military-companies and https://chinaselectcommittee.house.gov/media/press-releases/moolenaar-american-companies-governments-should-cut-ties-with-new-pentagon-listed-chinese-military-companies - [2026-06-08] The June 2026 removals were based on determinations that the entities do not operate in the US. As of 2026-06-09, one listed entity had sued for removal, but I did not find a CATL lawsuit. Source: https://www.hsfkramer.com/notes/sanctions/2026-posts/us-department-of-war-expands-section-120h-list-to-188-chinese-military-companies BOTTOM LINE: Large, prominent, US-active Chinese commercial firms such as CATL have essentially never been removed by lobbying alone. Removals have gone to firms without US operations or, rarely, after court losses by DoD, and CATL has not sued. The list was just refreshed in June 2026 with CATL kept, and the next scheduled refresh is probably after the window, so the base rate for removal by June 2027 is very low. The main upside risk is a political deal in US–China talks, and I found no sign of one. NOT FOUND: Any CATL lawsuit against DoD; any announced or reported DoD reconsideration decision on CATL; any trade-deal reporting that links CATL's delisting to US–China talks; and any other venue's odds or forecasts on CATL's removal. I did not search for this contract's own price.

YES means: CATL (Contemporary Amperex Technology Co., Ltd.) is fully removed from the Section 1260H list, in a DoD/DoW Federal Register notice or website list or announcement, by 2027-06-30 11:59 PM ET. A mere injunction or suspension of enforcement does not count. - [2026-06-10] The Federal Register notice (91 FR 35189) says the Pentagon must make additions or deletions "not less frequently than annually". It also says listed entities may request reconsideration, and it gives a dedicated mailbox. The statutory clock therefore forces a new notice by about June 2027, and each such notice is a chance to drop CATL. The statute sets no outcome for CATL, and the window is tight. https://www.federalregister.gov/documents/2026/06/10/2026-11571/notice-of-availability-of-designation-of-chinese-military-companies - [2026-06-10] The same notice shows the Pentagon is willing to delist. The removals it listed include Anhui Sun Create, China National Chemical Engineering, CNOOC China Ltd and COSCO Shipping Finance. DLA Piper notes the notice gave no basis for the removals, so the Pentagon can delist without public reasoning. https://www.dlapiper.com/en/insights/publications/2026/06/dod-updates-and-expands-list-of-chinese-military-companies-operating-in-us-under-section-1260h - [2026-09-03] The WuXi AppTec injunction of 7 Aug found the Pentagon's one-sentence justification factually deficient. A cited 5.32% stake was an AVIC fund's own portfolio allocation, and WuXi's actual ownership was nearer 0.001%. This is a template for attacking thin listing rationales. The Pentagon did not explain CATL's listing either, and the Jan 2025 reports say it gave no reason. The injunction is preliminary, expressly permits redesignation, and covers only WuXi. https://www.gtlaw.com/en/insights/2026/9/biosecure-act-update-court-enjoins-wuxi-apptecs-1260h-designation-but-strategic-and-compliance-clocks-keep-running - [2026-09-03] Litigation raises the cost of keeping weakly supported listings. The court accepted evidence that customers and suppliers cancelled contracts within weeks as irreparable harm. CATL has comparable commercial exposure with Ford, Tesla and GM licensing. CATL could sue and use this precedent, but I found no sign that it has. Same GT source. - [2025-04-22] CATL has long said it was engaging DoD directly to "correct" what it calls an error. It has said its designation is a mistake and that it has never done military business. So its reconsideration track has been continuous since early 2025, not a new filing after the June 2026 list. This is also consistent with the 12 June 2026 statement that a reconsideration request is pending. https://exportcompliancedaily.com/article/2025/04/22/catl-seeks-removal-from-us-list-of-chinese-military-firms-2504190001?BC=bc_68092c89e796b - [2025-01-07] CATL's January 2025 listing came with a reconsideration process that had just been created. It was introduced alongside the FY25 NDAA requirement for written justification of removals. Crowell calls it likely a response to litigation, so the Pentagon built a formal off-ramp that it can apply to CATL. https://www.crowell.com/en/insights/client-alerts/new-year-updated-list-the-us-department-of-defense-updates-its-list-of-chinese-military-companies-with-ancillary-supply-chain-and-usg-contracting-impacts - [2026-04-15] Bloomberg describes CATL's campaign as senior-level and documented (video and extensive evidence) and says CATL "continues to pursue paths to win relief". That is the case for CATL as a motivated petitioner, though the same report says its co-founder judged the odds slim. Bloomberg also flagged US-China trade talks as a possible venue, ahead of the Trump-Xi summit. Delisting as a bargaining chip is therefore the most plausible non-legal path. https://www.ttnews.com/articles/catl-pentagon-china-blacklist - [2026-07-28] Holland & Knight report that the June update added 65 entities, 17 parents and 48 subsidiaries, and removed 10. The update came less than a month before the Section 805 procurement ban took effect. A further hardening is due on 30 June 2027, which reaches sub-tier suppliers. That date coincides with the market deadline and raises the pressure on CATL and its US licensees to get removal before then. https://www.hklaw.com/en/insights/publications/2026/07/department-of-war-updates-section-1260h MOST LIKELY PATH TO YES: The Pentagon's reconsideration review, or a CATL lawsuit modelled on WuXi, leads to a delisting. This would most likely appear in the annual notice due by about June 2027, or in an earlier ad hoc notice. Each of the following would have to hold: 1. The Pentagon concludes that CATL does not meet the criteria, or is willing to concede for diplomatic reasons. 2. It publishes this before 30 June 2027, rather than withdrawing or delaying the notice as it did in February and April 2026. 3. The list is republished in full, without CATL. BOTTOM LINE: The strongest YES case is the combination of a pending reconsideration request, an annual statutory update due about June 2027, and a court-validated attack on thin listing rationales. Even so, it needs the Pentagon to reverse a politically charged listing it reaffirmed in June 2026, so it is a low-odds route. NOT FOUND: Any DoD reply to CATL's reconsideration request. A CATL lawsuit. Any trade-deal text that links CATL to delisting. Any announced date for the next list notice. I did not fetch the war.gov page directly, and the Federal Register page I fetched had its entity list truncated.

YES means: DoD/DoW fully removes CATL (the parent entity) from the Section 1260H list, in a published list or notice, by 2027-06-30 11:59 PM ET. Suspension, an injunction or the removal of a subsidiary does not count. - [2026-06-05] CATL's own statement shows its reconsideration request was already filed before the June 8 list. DoD then re-listed CATL anyway, so the request has already been denied or ignored once in practice. The statement gives no filing date and no DoD response. https://www.catl.com/en/news/6832.html - [2026-06-10] The Federal Register notice (91 FR 35189, Docket DOD-2026-OS-1288) is the operative list. It names CATL among the entities that "qualify" and "operate directly or indirectly in the United States", and it removes only entities that DoD found lack a US nexus. CATL's own US-facing business, including the technology licensing and home-storage sales it advertises, works against that route. https://www.federalregister.gov/documents/2026/06/10/2026-11571/notice-of-availability-of-designation-of-chinese-military-companies - [2026-06-10] The notice says reconsideration requests and other correspondence go by email to a 1260H mailbox. It sets no deadline for DoD to decide and no appeal step. Section 1260H requires only that additions and deletions be considered "not less frequently than annually". So DoD can sit on CATL's request until the next list, with no violation of the statute. https://www.federalregister.gov/documents/2026/06/10/2026-11571/notice-of-availability-of-designation-of-chinese-military-companies - [2026-06-10] Timing arithmetic: the last list ran on 2026-06-10 (91 FR 35189), the one before it on 2025-01-07, and the Feb and Apr 2026 versions were pulled. The next annual deadline is about June 2027, which leaves only days before the 2027-06-30 close. Slippage of even a few weeks, as happened in 2025–26, pushes any delisting outside the window. Even an on-time list would have to drop a parent that DoD just re-affirmed. https://www.dlapiper.com/en/insights/publications/2026/06/dod-updates-and-expands-list-of-chinese-military-companies-operating-in-us-under-section-1260h - [2026-06-10] The June notice gives DoD's basis for listing other entities as SASAC ownership, MIIT or SASTIND affiliation, or "Little Giant" awards. These are broad, status-based grounds that CATL cannot easily rebut with evidence. In practice they are almost impossible to disprove, since a company would have to show it has no such affiliation or award. https://www.federalregister.gov/documents/2026/06/10/2026-11571/notice-of-availability-of-designation-of-chinese-military-companies - [2026-06-10] DoD widened the criteria and added many commercial firms (BYD, CALB, EVE Energy and others). That is the opposite of a de-escalation trend. Rivals CALB and EVE joining CATL on the list also reduces any case that CATL is singled out. https://www.wilmerhale.com/en/insights/client-alerts/20260611-pentagon-adds-65-new-entities-to-the-1260h-list-of-chinese-military-companies - [2026-06-08] Law-firm commentary says the removal of ten entities came without any stated basis. It gives no sign that a reconsideration request has ever produced a removal of a major US-active parent. DLA Piper advises using reconsideration "where factual circumstances or affiliations have materially changed". CATL has not claimed any such change. https://www.dlapiper.com/en/insights/publications/2026/06/dod-updates-and-expands-list-of-chinese-military-companies-operating-in-us-under-section-1260h - [2025-04-18] CATL publicly said it was "engaging directly with DoD" to correct the "error". Eighteen months later it is still listed, and it was re-confirmed on a second list. That is evidence the engagement is not working. https://exportcompliancedaily.com/article/2025/04/22/catl-seeks-removal-from-us-list-of-chinese-military-firms-2504190001?BC=bc_68092c89e796b - [2026-04-15] CATL's lobbying efforts were led by co-founder Pan, and Bloomberg's sources said he thought chances were slim. The same piece says it faces "staunch opposition" from lawmakers and national-security officials, and that recent suits by other firms have failed. https://www.ttnews.com/articles/catl-pentagon-china-blacklist - [2026-06] Separate statutory exposure to CATL (the FY24 NDAA battery procurement ban from 2027) and a House Select Committee report of 2026-05-21 targeting its banks show that Congress, not only DoD, is hostile. A removal would draw political fire and likely a hearing. This makes a quiet administrative delisting costly for the Pentagon. https://www.catl.com/en/news/6832.html - [2026-06] Resolution technicalities that help NO: (a) an injunction or suspension in a lawsuit does not count; (b) renaming, merger or a transfer to a successor does not count; (c) the removal must appear in a published DoD list or notice. CATL has not sued, so even the court route, which gave AMEC and Xiaomi their removals, is unavailable. Its listing is also based on the affiliation criteria and not on a procedural defect, which is what the 2026 remands turned on. https://www.federalregister.gov/documents/2026/06/10/2026-11571/notice-of-availability-of-designation-of-chinese-military-companies BOTTOM LINE: Removal needs a reversal of a determination DoD re-affirmed in June 2026 for a prominent, US-active firm, and the only scheduled chance falls in the last weeks before the deadline. Any slippage, or a repeat of the withdrawn-list episodes, makes NO the default. NOT FOUND: Any DoD answer to CATL's reconsideration request; any CATL lawsuit; the specific rationale DoD gave for CATL in the June 2026 notice (the fetched page was truncated); any report of a planned delisting; and any published date for the next list.