1260H名单已成为美国限制中国企业取得联邦合同与研究资金的实质管道，也被视为未来更严格制裁的前置信号。该名单自2020年仅20家起步，于2026年二月更新版扩增至187家，增幅达835%；此前2023年未有更新。此次版本涉及中国前100大市值企业约五分之一的规模，曾出现已知科技与制造核心企业如Tencent Holdings、CATL、DJI、Huawei、Semiconductor Manufacturing International Corp.、Yangtze Memory Technologies、ChangXin Memory Technologies、YMTC与CXMT等。至少有7家中国企业提起诉讼，且围绕名单运作的法律与游说产业在华府持续扩大。
二月名单回撤的关键争点是内部分歧：White House认为不得同时删除YMTC与CXMT，原因是当时全球记忆体供应紧缩已被描述为「前所未有危机」，且中国晶片企业退出名单可能被解读为削弱政策一致性。官方最终仍在2月13日发布后数分钟撤回，并未给出公开说明；与之呼应，法院过去以Xiaomi案裁定该程序曾「任意且乖离法理」，使五角大楼名单部门公信力受损。此后名单回到旧版本，更新暂停使投资人面临不确定性，Tencent聘用前官员John McEntee耗资400,000美元游说、CATL多次赴美交涉等案件显示，企业已同步采用诉讼、游说及跨部门沟通的混合路径。
In early February 2026, the Pentagon briefly published a draft 1260H list that added Alibaba Group Holding Ltd., Baidu Inc., and BYD Co., then withdrew it almost immediately after release, creating both market and diplomatic effects. This came on the eve of the planned Donald Trump–Xi Jinping summit and highlighted a policy oscillation between pressure and engagement. Because both Alibaba and Baidu are listed in the U.S., their shares dropped on the publication day, while both companies said they would contest the designation; Pentagon officials later said updates follow the statute and that additions or deletions are made at the administration’s discretion.
The 1260H list has evolved into a practical gate on federal contracts and research funding and a warning of potentially harsher controls. It grew from 20 entities at its 2020 start to 187 in the 2026 update, an 835% increase, with no update in 2023. That withdrawn draft reportedly covered roughly one-fifth of China’s top-100 companies by market value and included names often linked to China’s strategic sectors, such as Tencent Holdings, CATL, DJI, Huawei, YMTC, CXMT, and others connected to memory and defense-related supply chains. At least seven Chinese firms have sued, while lobbying and legal workstreams around designation decisions have intensified.
The rollback reflected internal discord over timing and strategy rather than a single coherent line toward China. White House officials said removing YMTC and CXMT was too risky while a global memory shortage was already severe for phones, cars, and AI data centers; yet the Pentagon still published the list with those removals, then pulled it minutes later on Feb. 13. In 2021, a court ruling against Xiaomi previously criticized the process as arbitrary and capricious, and people involved say that judgment has damaged the office’s credibility. Since the list has reverted to an older version, investors now face uncertainty, and firms are pursuing layered strategies—litigation, lobbying (including Tencent’s reported US$400,000 engagement with John McEntee), and Treasury-facing advocacy—while uncertainty persists and a full refresh is not clearly imminent.