Healthcare - China (H): China CRO/CDMO: limited impact from 1260H list; continue to prefer leaders

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Healthcare - China (H): China CRO/CDMO: limited impact from 1260H list; continue to prefer leaders

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Healthcare - China (H)

China CRO/CDMO: limited impact from

1260H list; continue to prefer leaders

Industry Overview

Announcement of an update to the Section 1260H list 09 June 2026

On 8 Jun, the US Department of Defense released an updated list under Section 1260H, Equity

containing “Chinese military companies” operating directly or indirectly in the US. The China

updated list includes companies across multiple sectors, including several healthcare- Healthcare

related names, such as WuXi AppTec, BGI Group, Complete Genomics and MGI Tech. David Li >>

Research Analyst

Linkage to the Biosecure Act Merrill+852 3508Lynch4531(Hong Kong)

The 1260H list is linked to the Biosecure Act. The Biosecure Act, enacted through the davidbo.li@bofa.com

FY26 NDAA at YE25, does not name specific companies in the statute. Instead, it Ethan Cui >>

defines biotechnology companies of concern (BCCs) through two routes: 1) companies ResearchMerrill LynchAnalyst(Hong Kong)

on the 1260H list that are involved in biotechnology equipment or services, as ethan.cui@bofa.com

determined by OMB; and 2) companies designated through an OMB-led national security Sandra Sun >>

process. The restrictions are not immediate, as several implementation steps are Merrill Lynch (Hong Kong)

required. OMB must first publish the initial BCC list, then issue implementing guidance sandra.sun@bofa.com

within 180 days. The FAR Council has up to one year to revise the FAR. Prohibitions

would take effect 60 days after the FAR revision for BCCs identified through the 1260H-

CRO: Contract Research Organizationlist, or 90 days for entities newly designated by OMB. Based on this timeline, we expect