export controls

Export Control Pressure Index Reads 33.9 as BIS Goes a Year Without an Entity List Addition and Beijing Keeps Countering

The Export Control Pressure Index, CrossGov.com’s new gauge of how hard Washington and Beijing are leaning on each other’s technology trade, reads 33.9 at the end of October 2026, in the Steady zone. The two halves of the reading point in opposite directions. On the US side the Commerce Department’s Bureau of Industry and Security has gone more than a year without adding a single company to the Entity List. On the Chinese side the Commerce Ministry has kept answering every American move, and in October it went further than it ever has with a draft list that would put large AI models under export control.

The reading

Measure Score Zone What it counts
Export Control Pressure Index 33.9 Steady Average of the three inputs
BIS rules 28.3 Steady 6 BIS rules published August to October
Entity List additions 10.8 Quiet 0 Entity List addition rules August to October
China countermeasures 62.5 High 5 Chinese measures from August 2 to October 31
US side only 19.6 Quiet Average of the two Federal Register inputs
Quiet: 0 to 19QuietSteady: 20 to 39SteadyRising: 40 to 59RisingHigh: 60 to 79HighEscalation: 80 to 100EscalationNow: 33.933.9Steady, reading of October 31, 2026
The index runs from 0 to 100. Quiet is 0 to 19, Steady 20 to 39, Rising 40 to 59, High 60 to 79 and Escalation 80 to 100.
QuietSteadyRisingHighEscalation020406080100BIS rules6 rules in 3 monthsBIS rules: 28.3, 6 rules in 3 months28.3Entity List additions0 addition rules in 3 monthsEntity List additions: 10.8, 0 addition rules in 3 months10.8China countermeasures5 measures in 90 daysChina countermeasures: 62.5, 5 measures in 90 days62.5
Each input is scaled from 0 to 100 before averaging. The two US inputs are ranked against the previous five years.

Washington has stopped adding names

BIS published 6 rules in the three months to October and none of them added a company to the Entity List. The last addition rule appeared on October 9, 2025, when 29 entities were added. Since then the list has seen one revision rule and one removal, both on August 24, 2026. For a tool that BIS used 17 times in 2023 alone, that is a long silence.

Year BIS rules Entity List addition rules
2019 20 9
2020 38 8
2021 36 12
2022 36 10
2023 43 17
2024 52 11
2025 23 6
2026, through October 12 0

The rules BIS did publish this year mostly loosen or tidy. Three of the twelve streamline drone exports. Others give the United Arab Emirates better treatment, take Cambodia out of the arms embargo country group, extend a deadline for approved chip designers and move license review for some advanced computing chips from a presumption of denial to case by case. The tightening is narrow: a September 24 rule against stockpiling polysilicon and an August defense priorities order on recoverable critical minerals.

024682024-11, All BIS rules: 62024-11, Entity List addition rules: 12024-12, All BIS rules: 62024-12, Entity List addition rules: 22025-01, All BIS rules: 82025-01, Entity List addition rules: 201/252025-02, All BIS rules: 12025-03, All BIS rules: 22025-03, Entity List addition rules: 22025-04, All BIS rules: 104/252025-05, All BIS rules: 107/252025-09, All BIS rules: 62025-09, Entity List addition rules: 12025-10, All BIS rules: 12025-10, Entity List addition rules: 110/252025-11, All BIS rules: 22025-12, All BIS rules: 12026-01, All BIS rules: 201/262026-02, All BIS rules: 12026-04, All BIS rules: 104/262026-07, All BIS rules: 207/262026-08, All BIS rules: 52026-09, All BIS rules: 110/26All BIS rulesEntity List addition rulesRules published per month, last 24 months
Monthly count of BIS final and interim rules, with the Entity List addition rules among them.

The quiet has a reason. The trade truce struck in fall 2025 suspended the affiliates rule, which would have extended Entity List restrictions to companies at least 50 percent owned by listed firms, along with China’s October 2025 rare earth package. Both suspensions ran to November 10, 2026, and the truce has since been stretched to January 10, 2027, as covered in our truce post. Adding Chinese names to the list would put that bargain at risk, so Washington has used enforcement and license policy instead. Applied Materials paid about $252 million in February to settle export violations.

Beijing keeps the pressure on

China has not mirrored the pause. Its Commerce Ministry put 10 US defense and rare earth firms on its own export control list on June 22, after the Pentagon’s 1260H list update, and 14 EU firms on July 24, a day after Brussels sanctioned Chinese companies for helping Russia. Those two fall just outside the index window. What falls inside it:

Date Chinese measure
August 5, 2026 Case-by-case review of drones, key components and drone technology bound for the US
August 5, 2026 Trade ban on six US entities
August 5, 2026 Business ban on a US testing firm that worked with the FCC
August 5, 2026 National security probe of imported printing software and office equipment
October 16, 2026 Draft export control list of 40 technologies, 23 of them in AI

The August package answered the FCC’s ban on imports of Chinese drones and the Department of Homeland Security’s addition of 43 Chinese companies to its forced labor entity list. The October draft is the bigger signal. Drawn up by the Commerce and Science ministries, it would bring large language models, AI agents, chip designs and computing clusters under export control, with model weights and source code covered above set performance levels. Fourteen of the 40 items would be banned outright and 26 would need a license. Open-source releases and API or app access are exempt. Comments close November 15.

Five years of US pressure

QuietSteadyRisingHighEscalation020406080100202120222023202420252026High 96.3 (2023-02)Low 0.4 (2025-06)Now 19.6
The US side of the index, the average of the two Federal Register inputs, by month since March 2020.

The US side has rarely been this low for this long. It peaked at 96.3 in February 2023, when four Entity List addition rules came out in that month alone, and reached its low of 0.4 in June 2025, after three months with two BIS rules and no additions. Of the 80 monthly readings since March 2020, only 17 have been as low as today’s 19.6, and 15 of those came after March 2025. From 2020 through 2024 the US side spent 32 of 58 months in the High or Escalation zones. The China input has no comparable history yet, so the full three-input index starts with this reading.

What to watch

Date Event What it would move
November 10, 2026 Original end date of the affiliates rule suspension and of China’s rare earth suspension Both inputs, if either side lets a measure lapse
November 15, 2026 Comment deadline on China’s draft AI and technology export list China countermeasures, once the list becomes final
Any day The first BIS Entity List addition rule since October 2025 Entity List additions would jump from the bottom of its range
January 10, 2027 End of the extended truce All three inputs

Bottom line

Export control pressure between the two countries is lopsided right now. Washington has frozen its most visible tool to protect a trade truce and has spent 2026 easing more rules than it tightened, so the US side of the index sits near the bottom of its five-year range. Beijing has kept listing, banning and probing in answer to every American step, and its draft AI export list shows it now treats its own technology as something to control as well as protect. The headline reading of 33.9 looks calm, but it rests on a pause with a fixed end date. If the truce lapses in January, or BIS resumes Entity List additions, the US inputs can move from Quiet to High within one quarter, as they did repeatedly between 2020 and 2024, and China has shown it will answer within days.

Method. The index averages three inputs, each scaled from 0 to 100. BIS rules and Entity List additions are the counts of rules (final and interim final) published by the Bureau of Industry and Security in the Federal Register over the last three months, ranked against every three-month window in the previous five years. China countermeasures counts export control, trade ban and national security measures announced by Chinese ministries in the last 90 days, scored at 12.5 points per measure up to 100, until a year of tracked data allows the same ranking. Zones: 0 to 19 Quiet, 20 to 39 Steady, 40 to 59 Rising, 60 to 79 High, 80 to 100 Escalation. Reading as of October 31, 2026.