Taiwan should review past U.S. export control listings: Think tank

Taipei, Aug. 29 (CNA) Taiwan should review entities placed on the United States export control list before 2022 to close gaps in its own controls, rather than automatically adopting every U.S. designation, a Taiwan-based researcher said.

The report said such a review would address enforcement loopholes caused by entities appearing on the U.S. list but not Taiwan's, which can leave Taiwanese companies free of liability under end-user control rules and the government without a legal basis to act under those rules.

The recommendation was made in "Alignment and Challenge: Taiwan's End-User Export Controls in the Techno-Geopolitical Era," a report authored by Wang Tsai-yi (王采逸), a non-resident fellow at the Research Institute for Democracy, Society and Emerging Technology (DSET), and released Friday.

"Many well-known Chinese technology companies and research institutes are not yet included" on Taiwan's Strategic High-Tech Commodities (SHTC) Entity List, Wang told CNA in written replies Saturday.

The report found that Taiwan has closely aligned the SHTC list with the U.S. Bureau of Industry and Security (BIS) Entity List since 2022.

By the end of 2025, 1,490 entities appeared on both lists, according to the report.

Taiwan had added 55.36 percent of entities placed on the BIS list between 2018 and 2025 to its own list, with the figure rising to 79.7 percent for U.S. additions made between 2023 and 2025.

Wang confirmed that the percentages represented the share of U.S.-listed entities also included by Taiwan. The roughly 7 percent overlap between the U.S. and Japanese lists was calculated using the same method, she said.

The overlap between the Taiwan and U.S. lists surged to 60.79 percent in 2022 and remained above 70 percent thereafter, a shift the report linked to Taiwan's growing importance in global supply chains and Russia's invasion of Ukraine.

Among the 1,204 entities mutually added by Taiwan and the U.S. after 2018, 82 percent were Chinese or Russian, the report said.

Many were in computer and electronics manufacturing, professional, scientific and technical services and linked to China's military modernization, it added.

Despite the recent alignment, the failure to review earlier U.S. designations has created enforcement gaps, according to DSET.

Wang cited Chinese memory chipmaker Fujian Jinhua, which was added to the BIS list in 2018 but not on Taiwan's SHTC list.

Reports that Fujian Jinhua could serve as an "underground fab" for Huawei suggest additional export controls may be needed, she said.

Wang clarified that Taiwanese companies trading with entities absent from the SHTC list would not violate Taiwan's end-user control rules.

Whether they violated other export controls, including restrictions on particular commodities, would depend on what was exported, she said.

To address the gaps, Wang said the International Trade Administration should compare the two lists, focusing on records from before 2022.

"Rather than incorporating all of the entities that are left out, the administration should decide which are so prominent that they should be included in the SHTC Entity List, based on Taiwan's economic security concerns," she said.

The review would not require legislative amendments, Wang said, noting that the administration, which oversees the SHTC list, made a large-scale revision in June 2025 without changing the law.

Wang cited the appointment of an export control officer at the American Institute in Taiwan in 2024 and Taiwan's commitments under the U.S.-Taiwan Agreement on Reciprocal Trade as evidence of growing bilateral cooperation on export controls.

However, the report said Taiwan should play a role beyond mere compliance in the U.S.-led system.

Taiwan's central position in global technology supply chains gives it practical knowledge of export-control bottlenecks that could inform both its own policies and international cooperation, the report said.