Taipei: Taiwan should reassess entities listed on the United States export control list before 2022 to address enforcement gaps in its own controls, rather than automatically adopting every U.S. designation, according to a Taiwan-based researcher.
According to Focus Taiwan, the recommendation comes from a report titled "Alignment and Challenge: Taiwan's End-User Export Controls in the Techno-Geopolitical Era," authored by Wang Tsai-yi, a non-resident fellow at the Research Institute for Democracy, Society and Emerging Technology (DSET). The report points out that gaps exist due to entities appearing on the U.S. list but not on Taiwan's, leaving Taiwanese companies free of liability under end-user control rules and the government without a legal basis to act.
Wang noted that many prominent Chinese technology companies and research institutes are absent from Taiwan's Strategic High-Tech Commodities (SHTC) Entity List. Since 2022, Taiwan has closely aligned its SHTC list with the U.S. Bureau of Industry and Security (BIS) Entity List, with 1,490 entities appearing on both lists by the end of 2025.
Taiwan added 55.36 percent of entities from the BIS list between 2018 and 2025, with the share rising to 79.7 percent for U.S. additions made between 2023 and 2025. The overlap between the U.S. and Taiwan lists surged to 60.79 percent in 2022 and remained above 70 percent thereafter, reflecting Taiwan's growing global supply chain role and the geopolitical impact of Russia's invasion of Ukraine.
The report highlighted that among the 1,204 entities jointly added by Taiwan and the U.S. after 2018, 82 percent were Chinese or Russian, often linked to computer and electronics manufacturing, professional services, and China's military modernization.
Despite this alignment, DSET emphasizes that failure to review earlier U.S. designations has created enforcement gaps. Wang cited the example of Chinese memory chipmaker Fujian Jinhua, added to the BIS list in 2018 but absent from Taiwan's list. Reports suggest Fujian Jinhua could serve as an "underground fab" for Huawei, indicating the need for additional export controls.
Wang clarified that Taiwanese companies trading with entities not on the SHTC list would not violate Taiwan's end-user control rules. The legality of their actions would depend on the specific commodities exported.
To address these gaps, Wang recommended that the International Trade Administration compare the U.S. and Taiwan lists, focusing on pre-2022 records. She suggested that only prominent entities, based on Taiwan's economic security concerns, should be added to the SHTC Entity List.
Wang noted that such a review would not require legislative amendments, citing a large-scale revision of the SHTC list in June 2025 without legal changes. She also highlighted 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.
The report concluded that Taiwan should play a more active role beyond mere compliance in the U.S.-led export control system, leveraging its central position in global technology supply chains to inform both its policies and international cooperation.