Recent federal actions expand the Department of War's 1260H list and add restrictions on doing business with certain Chinese military-linked companies.
The BIOSECURE Act, now a part of FY26 National Defense Authorization Act (NDAA), will prohibit federal agencies and organizations receiving federal funds from procuring or obtaining any biotechnology supplies/services from “…biotechnology companies of concern based on a list of suggested entities that shall be provided by the Secretary of Defense in coordination with the Attorney General, the Secretary of Health and Human Services, the Secretary of Commerce, the Director of National Intelligence, the Secretary of Homeland Security, the Secretary of State, and the National Cyber Director.” These companies will be added to the Department of War (DoW) 1260H list and will prohibit the university from purchasing supplies/services from these companies with federal funds or using supplies/services in support of a federal grant/contract.
While the list of biotechnology companies of concern list has not been finalized, the original BIOSECURE Act language in 2024 identified five Chinese biotechnology companies: BGI Group, MGI, Complete Genomics, WuXi AppTec and WuXi Biologics. In December 2025, Congress sent a letter to the DoW urging them to expand the 1260H list to include a set of Chinese firms that support “military-civil fusion” (MCF) and advance People’s Liberation Army (PLA) capabilities across various sectors. Biotechnology companies referenced in that effort included WuXi AppTec, WuXi Biologics, and WuXi XDC and GenScript Group.
On June 8, 2026, the Department of War formally updated the Section 1260H list to include WuXi AppTec, identifying it as a “Chinese military company” operating directly or indirectly in the United States. This designation represents a significant development in the implementation of the BIOSECURE Act, as inclusion on the 1260H list is a key mechanism through which entities may be identified as “biotechnology companies of concern.”
Departments and researchers should review current suppliers and investigate alternate supply chain vendors in advance of potential restrictions in the 2027-2028 timeframe.
In addition, all researchers are encouraged to use Ohio State’s International Risk Assessment Tool to request a review of potential risk associated with foreign institutions and companies prior to engagement.
Updated June 15, 2026