Defense contractors will be required to comply with the Section 1260H Chinese Military Companies (CMC) list beginning in June 2026 for contractors that work with individuals or entities lobbying for CMCs. The restriction expands in June 2027 to cover contractors sourcing from or otherwise doing business with 1260H-listed entities. Coverage from Exiger.
What 1260H is
The 1260H list — maintained by DoD under Section 1260H of the FY2021 NDAA — identifies companies the U.S. government has determined are owned or controlled by, or affiliated with, the Chinese military. The list is broader than the Section 889 restriction (which covers specific telecom companies) and reaches into manufacturing, biotech, drone, and AI suppliers.
Two-stage enforcement timeline
- June 2026: contractors that work with individuals or entities that lobby for CMCs face restriction
- June 2027: contractors sourcing from or doing business with 1260H entities face restriction
Why this is harder than 889
Section 889 has bright-line covered-equipment lists. 1260H requires you to check the 1260H entity list (which evolves), trace third-party lobbying relationships, and — by 2027 — screen your supply chain at multiple tiers. There's no simple "use Cisco instead" workaround.
What to do
- Pull the current 1260H list and run it against your supplier roster today
- Audit your government-affairs vendors — do any lobby for 1260H-listed companies?
- Add 1260H certification language to subcontractor flow-downs ahead of June 2026