DoD 1260H List Targets Cirrus Over AVIC Ties
Alongside Cirrus, two other U.S.-registered AVIC entities were named.
Cirrus Design Corporation — doing business as Cirrus Aircraft — is among the Chinese entities the U.S. Department of Defense added to its Section 1260H list of “Chinese military companies” on June 8.
The Duluth, Minnesota-based manufacturer, known for its SR-series piston-engine aircraft and the Vision Jet, was listed due to its parent company, the Aviation Industry Corporation of China (AVIC), a state-owned enterprise directly controlled by China’s State-owned Assets Supervision and Administration Commission.
The designation does not carry immediate economic sanctions, but it will restrict the Pentagon from contracting with the company starting June 30.
However, under Section 1260H, the Secretary of Defense has the authority to issue a national security waiver to continue contracting with a listed entity if they justify it to Congress (though such waivers are temporary and require detailed congressional justification).
It is important to clarify that the 1260H list is strictly a Department of Defense procurement restriction. It is not the same as the U.S. Commerce Department's "Entity List," which restricts exports of U.S. technology and components.
The 1260H list does not directly trigger comprehensive sanctions, nor does it prohibit the export of U.S. parts or technology to listed entities.
Cirrus can still buy U.S. engines and avionics freely (for now).
AVIC has owned Cirrus since 2011, when its subsidiary, China Aviation Industry General Aircraft (CAIGA), acquired the company for approximately $210 million in a deal that was cleared at the time by the U.S. Treasury committee responsible for reviewing foreign investments for national security concerns.
Cirrus listed a minority stake on the Hong Kong Stock Exchange in 2024, though AVIC retained an 80% controlling interest.
The company reported revenue of around $1.2 billion in 2024.
In July 2025, Utah Governor Spencer Cox blocked Cirrus from purchasing land near Provo Airport, citing the company’s AVIC ownership and a state law restricting land acquisitions by certain foreign entities.
Alongside Cirrus, two other U.S.-registered AVIC entities were named — engine manufacturer Continental Aerospace Technologies and parts supplier Align Aerospace.
However, U.S. private equity firm Arcline Investment Management announced on the same day the list was published that it had agreed to acquire Continental for $535 million, a deal that would return the company to U.S. ownership.
The Section 1260H list, established under the William M. “Mac” Thornberry National Defense Authorization Act (NDAA) for Fiscal Year 2021, does not carry automatic sanctions.
However, under Section 805 of the Fiscal Year 2024 NDAA, the Department of Defense is prohibited from entering, renewing, or extending contracts directly with listed entities starting June 30, with an indirect procurement ban following on June 30, 2027.
A 2025 amendment further clarified and expanded the DoD's authority to designate parent companies or subsidiaries based on a single qualifying entity.
While the direct contracting ban is expected to have limited short-term impact on Cirrus — its last major U.S. military contract was a $6.1 million order for 25 T-53A trainers for the U.S. Air Force Academy in 2011 — the designation adds complexity to the company’s regulatory environment and could affect market confidence, financing terms, and third-party contractor relationships.
Meanwhile, on June 18, Cirrus Aircraft’s Hong Kong-listed shares (ticker: 2507.HK) closed at HK$36.46, down 3.29% for the day. The stock traded within a 52-week range of HK$30.90 to HK$76.50.
The June 8 update was the largest expansion of the 1260H list to date, growing from 134 entities in the previous version to 188, encompassing 80 parent companies.
The list’s scope extended well beyond traditional defense and infrastructure sectors to include major technology, electric vehicle, battery, AI, and biotechnology companies.
Newly added entities included Alibaba, Baidu, BYD, NIO, CATL, SenseTime, Unitree Robotics, WuXi AppTec, and numerous others.
Other aviation and aerospace entities that remained on the list include COMAC, China Aerospace Science and Industry Corporation (CASIC), Aerospace CH UAV, and multiple AVIC subsidiaries such as AVIC Chengdu Aircraft, AVIC Shenyang, and Hongdu Aviation.
The Ministry called on Washington to rectify its approach and revoke the relevant measures, while warning that Beijing would take “resolute and effective countermeasures” to protect its companies' legitimate rights and interests.
Several listed companies, including BYD, Alibaba, Baidu, and WuXi AppTec, have publicly stated that their inclusion lacks legal basis and that they will pursue legal options to challenge the designation.
The political and symbolic significance of the list may outweigh its immediate commercial consequences, signalling an expansion of U.S. concerns about military-civil fusion/integration from traditional defence sectors to broader civilian technology industries.
The U.S. Congress has formally defined "military-civil fusion strategy" as "the strategy of the Chinese Communist Party aiming to mobilize non-military resources and expertise for military application, including the development of technology, improvements in logistics, and other uses by the People's Liberation Army."
The U.S. Department of Defense implements the definition through Section 1260H of the NDAA, using it to identify entities that contribute to China's military-civil fusion efforts.
The U.S. argues the strategy blurs the lines between commercial entities and state security apparatuses by integrating civilian technology, R&D, and production capacity into China's military supply chain.