By Edmund Xu, Michelle Phillips and Robert Kim
March 14, 2023
On March 2, the U.S. Department of Commerce announced restrictions on the export of certain technologies to the Ningbo Institute of Technology, a military aerospace research institute in China. The decision to include Ningbo Institute of Technology on the Bureau of Industry and Security (BIS) Entity List was taken in light of technology exports to the Chinese firm from the U.S. and other Western countries. The Ningbo Institute of Technology is an affiliate of a Chinese defense technology research university that had already been subject to U.S. export controls.
The Ningbo Institute of Technology was founded in 2018 as a joint venture between the city government of Ningbo and Beihang University, which is one of seven Chinese universities with close ties to China’s defense industry, collectively known as the "Seven Sons of National Defense." Beihang University – which was hit with BIS export restrictions in 2001 – was also the long-time academic home of Wu Zhe, a leading scientist in the development of China’s surveillance balloons.
The March 2 additions to the BIS Entity List include ten research institutes affiliated with Beihang University, including the "Ningbo Innovation Institute" – a direct translation of Ningbo Institute of Technology’s Chinese name. However, its official English name, Ningbo Institute of Technology, does not appear in the U.S. government announcement.
Because the Ningbo Institute of Technology itself was not on the Entity List prior to March 2, as a legally separate entity from Beihang University, it did not face the same restrictions as its parent institution. BIS has issued guidance, however, warning that any entity acting as "an agent, a front, or a shell company for [a] listed entity in order to facilitate transactions that would not otherwise be permissible" would likely be violating U.S. export control regulations.
Beihang University has a history of using intermediaries to acquire U.S.-origin technology, according to a 2020 investigation by the South China Morning Post. Last year, the U.S. Department of Justice indicted a former employee of a NASA contractor for "secretly funneling sensitive aeronautics software" to Beihang University through a third party company in Beijing.
The Ningbo Institute has worked to develop new aerospace technologies since it was established by Beihang University in 2018. As of December 2022, the two institutions held 140 joint patents related to aerospace technologies such as high-tech alloys, UAV systems, aircraft systems, electric circuitry, and propulsion methods, according to patent data. Researchers from Beihang University and the Ningbo Institute of Technology also co-authored a 2021 paper on air-to-air missiles, describing wind tunnel experiments that assess the predictability and dynamics of the missiles and their in-flight control maneuvers.
The Ningbo Institute warned potential suppliers in a 2020 tender solicitation document that they "could be added" to the Entity List. Nevertheless, the institute continued to procure high tech testing equipment and other technologies made by companies based in the U.S. and other Western countries, to further their aerospace research.
From 2021-2023, the Ningbo Institute purchased U.S.-origin printed circuit board design and simulation software from the U.S. developer’s Chinese partner, and a fatigue testing machine manufactured in the U.K. by a U.S.-based multinational, according to trade data reviewed by Kharon.
The Ningbo Institute also procured electronics from Europe, including a hot wire calibrator and a hot wire anemometer from Denmark, a high speed image analysis system from Germany, and a multi-channel high-precision charge amplifier from Switzerland, records show.