Reference
Export Controls
The main rules since 2018, what can still be sold to China, and China's share of revenue at 24 firms, from their filings.
The interactive page moves the board to any date since 2018 and draws each firm's China share as a chart.
What can be soldOn 23 October 2026
AI chips up to the H200
Case by case
Case by case below 21,000 TPP and 6,500 GB/s of memory bandwidth, with conditions
Data center accelerators up to the H200's level: the A100 and H100, the cut-down A800, H800 and H20, the H200 and AMD's MI325X. Since 15 January 2026, license applications to export chips below 21,000 TPP and 6,500 GB/s of memory bandwidth from the United States to China or Macau are reviewed case by case. The exporter must certify, among other things, that US supply is sufficient and that a third party in the United States has tested the chips.
AI chips above the H200 band
Presumption of denial
Denial stays for chips at or above 21,000 TPP or 6,500 GB/s of memory bandwidth
Data center accelerators at 21,000 TPP or more, or with 6,500 GB/s or more of memory bandwidth, such as Nvidia's Blackwell B200. License applications to export them to China or Macau are reviewed with a presumption of denial.
Chipmaking tools
Case by case
Foreign-owned fabs in China lose their blanket approval for US tools (VEU)
Semiconductor manufacturing equipment and the software that runs it. A license is needed. Applications for advanced fabs meet a presumption of denial, and the rest are reviewed case by case.
Dutch and Japanese controls
Case by case
Japan adds more chipmaking tools, such as etch, deposition and inspection tools, to its license list
Advanced immersion DUV scanners (machines that print chip patterns) and some measuring and inspection tools from the Netherlands, and the chipmaking equipment Japan added to its license list in 2023 and 2025. The Dutch controls cover exports to every destination outside the EU, and the Japanese controls cover every destination.
High-bandwidth memory
Presumption of denial
Denial for Chinese-headquartered buyers, approval for the rest
Memory stacks with more than 2 GB per second of bandwidth per square millimeter, wherever they are made, including foreign stacks that the direct product rule brings under US control. The license requirement covers only Macau and Country Group D:5, the US list of arms-embargoed countries that includes China. For buyers in China or Macau, approval is presumed if they are headquartered elsewhere, and denial if they are headquartered there. License Exception HBM still lets an exporter in the US or in Country Group A:5, a group of close US partners, ship stacks below 3.3 GB per second per square millimeter without a license. The stacks must go directly to a packaging site for the designer that bought them.
US goods and technology
Presumption of denialSuspended until 9 Nov 2026
Affiliates rule suspended until 9 November 2026
Anything subject to the US Export Administration Regulations (EAR), from processors to design software, when a firm on the Entity List is a party to the transaction. Each listing sets how license applications are reviewed.
Critical minerals to America
ProhibitedSuspended until 27 Nov 2026
Ban on exports to America suspended
Gallium, germanium, antimony, superhard materials and graphite sold to American buyers.
Critical minerals to everyone else
Case by caseSuspended until 10 Nov 2026
0.1 percent rule suspended on 7 November, before it took effect
The same gallium, germanium and antimony, plus graphite, seven medium and heavy rare earths and items related to tungsten, tellurium, bismuth, molybdenum and indium, sold anywhere but America. A license is required.
Foreign chips inside China
Restricted
Chinese restrictions leave most H200 licenses unused
American memory and Nvidia accelerators sold inside China, plus a Japanese deposition gas. These are Chinese measures on Chinese buyers. No export is involved.
AI chips to the rest of the world
Case by case
UAE joins Country Group A:5, and shipments to named recipients need no license
The top band of accelerators, ECCNs 3A090.a and 4A090.a, which need a license to or within any destination worldwide under the AI Diffusion Rule of January 2025. BIS stopped enforcing the rule in May 2025 and said it would issue a replacement. In the rule, License Exception AIA lets exporters ship them without a license to nineteen destinations, the United States and eighteen allies, listed in supplement no. 5 to part 740. License Exception LPP allows up to 26,900,000 TPP a year per recipient elsewhere. License applications for the nineteen are reviewed with a presumption of approval. The rest count against a cap of 790,000,000 TPP per country through 2027.
Money, stakes and tariffs
Policy
Taiwan wins tariff relief and pledges $250 billion of investment
Subsidies, state investment funds, government stakes in companies, procurement bars and tariffs. None of these is a license requirement.
- No licenseNone needed.
- RestrictedA government limits sales to some buyers or uses without banning them outright.
- Case by caseA license is required, and each application is judged on its own.
- Presumption of denialA license is required and will normally be refused. This is the usual policy for those on the Entity List, a US list of restricted foreign companies, institutes and individuals.
- ProhibitedNo license is available, or the item is banned outright.
- PolicyMoney and tariffs, which do not stop a shipment.
- SuspendedThe rule is on hold until the date shown. When the hold ends, the state beside it takes effect.
The timeline of AI chip export controls, 2018 to 202674 entries
20183 moves
ZTE denial order activated
The first time one US order halted most of a large Chinese electronics firm's production.
The Bureau of Industry and Security (BIS), the US Commerce Department's export control office, activated a suspended denial order against ZTE, a Chinese maker of telecom equipment and phones. The order was set to run for seven years, to March 2025. BIS had found that the company lied about disciplining the employees responsible for illegal shipments to Iran and North Korea. The order barred all US persons from exporting anything to ZTE. The ban cut off ZTE's supply of Qualcomm processors and its Android licensing, and most of its production stopped within weeks. ZTE settled on 8 June for a $1 billion penalty plus $400 million in escrow, a replaced board and a US-appointed compliance monitor.
83 FR 17644 · 15 CFR part 766www.federalregister.gov
ZTE denial order terminated
The only outright US export ban on this timeline ended in July 2018 after a settlement.
BIS terminated the April 2018 denial order and removed ZTE from the Denied Persons List. ZTE had met the terms of its 8 June settlement: a $1 billion penalty, $400 million placed in escrow, a replaced board and a US-appointed compliance monitor. A ten-year denial order remains in place but suspended. The April order is the only US measure on this timeline that barred exports outright.
83 FR 34825 · 15 CFR part 766www.govinfo.gov
Fujian Jinhua added to the Entity List
US toolmakers stopped deliveries mid-installation, and Jinhua's DRAM fab never reached volume production.
BIS added Fujian Jinhua Integrated Circuit, a state-backed DRAM memory-chip start-up, to the Entity List, a US list of foreign parties that need a license to receive some or all US-regulated items. Jinhua's entry required a license, with a presumption of denial, for all items subject to the Export Administration Regulations (EAR), the US rules on commercial exports. The End-User Review Committee said the firm posed a significant risk of activities contrary to US national security. BIS separately warned that new Chinese DRAM capacity threatened the viability of US suppliers of military memory. The listing stopped deliveries of Applied Materials, Lam and KLA tools mid-installation, and the fab never reached volume production. It was the first use of the Entity List against a Chinese memory maker and the model for later chip listings.
83 FR 54519 · 15 CFR 744.11www.federalregister.gov
20194 moves
Huawei and 68 affiliates added to the Entity List
US suppliers needed a license to sell Huawei anything, chips included.
BIS listed Huawei Technologies and 68 non-US affiliates across 26 destinations, requiring a license with a presumption of denial for every item subject to the EAR. The listing ended Huawei's access to Google Mobile Services, Intel and Xilinx parts and US chip design (EDA) software. BIS added a further 46 affiliates in August 2019 and 38 more in August 2020.
84 FR 22961 · 15 CFR 744.11www.federalregister.gov
Japan requires individual licenses for three chemicals sold to South Korea
Each export of the three chemicals to South Korea needed its own license from 4 July 2019.
From 4 July 2019, Japan's Ministry of Economy, Trade and Industry (METI) required exporters to get an individual license to ship fluorinated polyimide, resist (photoresist) and hydrogen fluoride to South Korea. The bulk licenses that had covered the three items no longer applied. The change also covered their technology, which METI said may include technology transferred with exports of manufacturing equipment. METI said the relationship of trust with South Korea, including on export control, "has been significantly undermined". It also said it had found sensitive items exported to South Korea with inadequate management by companies. On the same day METI opened public comment on removing South Korea from its list of so-called white countries.
Foreign Exchange and Foreign Trade Act, articles 25(1) and 48(1)web.archive.org
Japan removes South Korea from its preferred trade partner list
South Korea lost access to Japan's general bulk licenses, and exports to it came under catch-all control.
The Japanese cabinet approved an order removing South Korea from Appended Table III of the Export Trade Control Order, the countries often called the white list or preferred trade partner list. The order was promulgated on 7 August and took effect on 28 August 2019. Exporters could no longer use general bulk licenses for goods and technology sent to South Korea. Those exports also came under catch-all control, which requires a license for unlisted goods and technology that could have military uses or serve weapons of mass destruction. Special general bulk licenses, granted to exporters that meet higher standards, remained available. METI regrouped destinations into Groups A to D and placed South Korea in Group B. Fluorinated polyimide, resist and hydrogen fluoride had needed individual licenses since 4 July. METI said it would grant them if exports were verified as legitimate private transactions.
Export Trade Control Order (Cabinet Order No. 378 of 1949), Appended Table IIIweb.archive.org
South Korea removes Japan from its white list
South Korea dropped Japan from its own fast-track trade list and took Japan's export curbs to the WTO.
South Korea's Ministry of Trade, Industry and Energy (MOTIE) removed Japan from its white list of countries with fast-track trade status, with immediate effect on 18 September 2019. South Korean exports to Japan related to weapons production faced longer permit applications and more paperwork. The ministry said the change aimed to improve South Korea's export control system and was not retaliation against Japan. Japan had removed South Korea's fast-track status in late August, after tightening exports to South Korea of three materials used in the chip and display industries. South Korea had also filed a World Trade Organization (WTO) dispute over the Japanese export curbs.
20204 moves
Foreign Direct Product Rule extended to Huawei chip designs
Washington used control of US design tools to stop TSMC building Huawei's chips.
BIS amended General Prohibition Three, the foreign direct product rule. Foreign-made chips designed by Huawei or its chip unit HiSilicon became subject to the EAR when they were the direct product of US-origin software or technology. The rule covered HiSilicon's Kirin phone chips and Ascend AI chips made by TSMC, the Taiwanese contract chipmaker, even though the chips contained no US content. TSMC stopped taking new HiSilicon orders within days and stopped shipments after 14 September 2020. This was the first time Washington used control of US design tools to stop a foreign foundry serving a foreign customer.
85 FR 29849 · 15 CFR 736.2(b)(3)(vi)www.federalregister.gov
Huawei FDPR broadened to any chip made with US equipment
Because almost every advanced fab runs American tools, even off-the-shelf chips became unavailable to Huawei.
BIS widened the May 2020 rule so that any foreign-produced item made with US-origin semiconductor equipment or software needs a license when Huawei is a party to the transaction. The requirement applies whatever firm designed the item. BIS also added 38 more Huawei affiliates in 21 countries and let the Temporary General License expire. Because almost every advanced fab uses Applied Materials, Lam or KLA tools, the rule made even off-the-shelf chips unavailable to Huawei. This rule created the equipment-based direct product test that BIS reused two years later in its China-wide rules.
85 FR 51596 · 15 CFR 736.2(b)(3)(vi); 744.11www.federalregister.gov
China's Export Control Law
The law behind every Chinese export control since 2020, from gallium licensing in 2023 to rare earth rules in 2025.
The Standing Committee of the National People's Congress adopted a single statute for export control, in force from 1 December 2020. It authorizes control lists, licenses, and end-user and end-use certificates. It also authorizes a list of foreign parties that may be barred from buying, controls over reexports of Chinese-origin items, and countermeasures against states that use export controls against China. Every Chinese export control since, from the gallium licensing of 2023 to the rare earth rules of 2025, has been issued under it.
Export Control Law of the People’s Republic of China, article 49exportcontrol.mofcom.gov.cn
SMIC added to the Entity List
The listing ended SMIC's plan to buy an EUV scanner, but SMIC still reached 7 nm with DUV immersion scanners.
BIS added the Chinese chipmaker Semiconductor Manufacturing International Corporation (SMIC) and ten related entities to the Entity List. It cited China's military-civil fusion doctrine and evidence of activities between SMIC and entities of concern in the Chinese military industrial complex. Licenses for items uniquely required for production at 10 nm and below carry a presumption of denial, while less advanced items are reviewed case by case. The listing ended SMIC's plan to buy an extreme ultraviolet (EUV) scanner, a machine that prints chip patterns, from the Dutch firm ASML. The Dutch government had been withholding a license for that scanner since 2019. Even so, by 2022 SMIC had reached a 7 nm-class node with deep ultraviolet (DUV) immersion scanners, printing its finest layers in several passes.
85 FR 83416 · 15 CFR 744.11www.federalregister.gov
20212 moves
EU's new dual-use export regulation enters into force
The EU's dual-use export rules took effect, letting the Commission update the control list by delegated act.
The European Union's new Export Control Regulation for dual-use items, civilian goods and technology with possible military or security uses, entered into force on 9 September 2021. It replaced the EU's 2009 rules. The European Commission said the regulation builds on the Wassenaar Arrangement, the multilateral export control framework behind many of the restrictions it imposes. The regulation lets the Commission amend the list of controlled items or destinations by delegated act, a simplified procedure. The Commission said the new framework would also let the EU pool expertise on emerging dual-use technologies such as advanced computing.
Regulation (EU) 2021/821ec.europa.eu
Italy vetoes a Chinese purchase of Applied Materials' Italian unit
Italy blocked a Chinese firm from buying an Applied Materials unit after the industry minister cited the semiconductor sector.
Italy's government blocked Zhejiang Jingsheng Mechanical, a Chinese company, from buying Applied Materials' screen printing equipment business in Italy through a joint venture with the US group's Hong Kong arm. Zhejiang Jingsheng disclosed the veto in a Hong Kong filing on 23 November 2021. Two government sources told Reuters the cabinet had decided on 18 November on the recommendation of Industry Minister Giancarlo Giorgetti. The sources said Giorgetti had argued that the takeover could have consequences for the strategic semiconductor sector. The joint venture was also meant to take over Applied Materials' wafer equipment business in Singapore and its assets in China. In April 2021 the government had stopped Shenzhen Invenland Holdings, another Chinese company, from buying a controlling stake in a maker of semiconductor equipment. Italy uses its golden powers to block bids in industries it considers strategic.
20227 moves
CHIPS and Science Act signed
Federal money for American fabs came with a ten-year bar on expanding capacity in China.
Public Law 117-167 authorized $52.7 billion for US semiconductors, including $39 billion in manufacturing incentives, $13.2 billion for R&D and workforce and $500 million for international supply-chain work. The law also provided a 25 percent advanced manufacturing investment tax credit. Companies taking incentives are barred for ten years from materially expanding advanced capacity in China or other countries of concern. Commerce's final awards included about $6.6 billion for TSMC Arizona, $4.745 billion for Samsung's Texas sites and $7.86 billion for Intel.
Public Law 117-167www.govinfo.gov
License requirement on design software for gate-all-around chips
Software for designing the newest transistor structure needed a license from October 2022, years before BIS's 2025 letters on chip-design software.
In December 2021 the Wassenaar Arrangement, the forum in which governments agree common export control lists, decided to control four emerging technologies. BIS wrote those decisions into US rules. For one of them it created ECCN 3D006, a new entry in the US list of controlled items. The entry put a national-security license requirement on electronic computer-aided design software specially designed for developing integrated circuits with gate-all-around transistors. The rule called that transistor structure key to processes at 3 nm and below. The rule was published on 15 August 2022, and the 3D006 control took effect on 14 October 2022. The requirement covers exports to China.
87 FR 49979 · 15 CFR part 774, supplement no. 1 (ECCN 3D006)www.federalregister.gov
First license requirement on A100 and H100 exports to China
Nvidia needed a license to sell its top chips in China and answered within weeks with the cut-down A800.
Nvidia disclosed in an 8-K filing that the US government had imposed a new license requirement on 26 August 2022. It covered exports of the A100, the A100X and the forthcoming H100 to China, Hong Kong and Russia. It also covered DGX systems built on those chips and any future chip at equivalent performance. Nvidia said about $400 million of third-quarter China sales were at risk. AMD received a parallel restriction on the MI250. Within weeks Nvidia offered the A800, which kept the A100's computing power but cut its interconnect bandwidth, the speed of its links to other chips, from 600 to 400 GB/s.
NVIDIA Form 8-K, 31 August 2022www.sec.gov
October 2022 rules on advanced computing and semiconductor equipment
China lost access to top chips, the tools to make them, and American engineers.
BIS created ECCN 3A090 and imposed China-wide controls on advanced chips, capturing the A100 and H100. The controls covered chips with a total processing performance (TPP), the rules' measure of computing power, of 4,800 or more, combined with interconnect bandwidth of 600 GB/s or more. New foreign direct product rules extended the chip controls to such chips and computers made outside the United States with US technology or software. Equipment controls covered fabs making logic at 16/14 nm or below or with non-planar transistors, DRAM at 18 nm half-pitch or below and NAND with 128 layers or more. US persons needed a BIS license to support advanced chipmaking in China. The interim final rule was published on 13 October. Parts of §§742.6 and 744.23 and the new equipment ECCN 3B090 took effect on 7 October, and §744.6 on 12 October. The chip ECCNs 3A090 and 4A090, the direct product rules and the Entity List changes took effect on 21 October.
87 FR 62186 · 15 CFR 742.6(a)(6), (b)(10); 744.6; 744.23; 734.9www.federalregister.gov
Germany blocks Chinese investment in two chipmakers
Berlin vetoed a Chinese-owned firm's purchase of Elmos's chip factory and blocked investment in ERS Electronic.
The German government blocked Chinese investment in two domestic semiconductor producers after the deals raised concerns about national security and the flow of sensitive know-how to China. It vetoed the takeover of the chip factory of Elmos, a company based in Dortmund, by Silex, a Swedish subsidiary of the Chinese group Sai Microelectronics. Government sources told Reuters it also blocked investment in ERS Electronic, a company in Bavaria that had been exploring investment from a Chinese private equity firm. Economy Minister Robert Habeck said that in the semiconductor sector the government wanted to protect the technological and economic sovereignty of Germany and Europe. Sai Microelectronics said it deeply regretted the decision.
UK orders Nexperia to sell Newport Wafer Fab
Britain ordered a Chinese-owned firm to sell at least 86 percent of its biggest chip factory, citing national security.
The British government ordered Nexperia, a Chinese-owned technology company headquartered in the Netherlands, to sell at least 86 percent of Newport Wafer Fab, Britain's biggest microchip factory. Nexperia had taken its stake to 100 percent in July 2021. The order followed a national security assessment under a law in force since January 2022. The law lets the government scrutinize and potentially block acquisitions in sensitive sectors, including deals completed since November 2020. The government cited a national security risk from the technology and know-how that compound semiconductor activities at the site could yield. Nexperia said it did not accept the concerns and would appeal.
National Security and Investment Act 2021, section 26 final orderwww.reuters.com
NDAA section 5949 bars federal buying of Chinese chips
A federal procurement ban passed in 2022 that takes effect in December 2027.
Section 5949 of the National Defense Authorization Act (NDAA) for fiscal 2023 covers semiconductors designed or made by SMIC, ChangXin Memory (CXMT) or Yangtze Memory (YMTC), or by their subsidiaries and successors. It bars executive agencies from buying electronic parts, products or services that contain them. It also bars agencies from contracting with a firm to obtain parts or products that use other parts or products containing those chips. The bar takes effect five years after enactment, on 23 December 2027. The FAR Council, which writes federal procurement rules, issued its proposed implementing rule on 17 February 2026.
Public Law 117-263, section 5949www.federalregister.gov
202310 moves
Japan allows special bulk licenses for three chemicals sold to South Korea
The three chemicals joined Japan's special bulk license system for exports to South Korea from 23 March 2023.
From 23 March 2023, Japan's Ministry of Economy, Trade and Industry (METI) covered exports of hydrogen fluoride, fluorinated polyimide and resists to South Korea under its Special General Bulk Export License system. The change also covered transfers of their technology. METI described the change as a review of how it handles exports of the three items to South Korea under the Foreign Exchange and Foreign Trade Act. License applications for the three items moved from METI's Trade Security Inspection Division to its regional bureaus and trade offices. METI asked exporters to keep checking end users and end uses under their internal export control rules.
METI circular notice, 23 March 2023web.archive.org
Micron barred from critical information infrastructure
China told operators of critical information infrastructure to stop buying Micron products, citing security risks.
China's Cybersecurity Review Office, a body outside the export-control system, concluded a review of Micron's products sold in China by finding that they carried serious security risks. It ordered operators of critical information infrastructure to stop buying them. The office called the review a necessary measure to protect national security and said foreign firms that follow Chinese law are welcome in the Chinese market. Micron told the SEC that customers headquartered in mainland China and Hong Kong were about a quarter of its worldwide revenue. It said roughly half of that revenue, a low-double-digit percentage of the worldwide figure, was at risk.
Cybersecurity Review Office notice, 21 May 2023www.cac.gov.cn
Japan returns South Korea to its preferred trade partner list
From 21 July 2023, general bulk licenses covered exports to South Korea, and those exports left catch-all control.
The Japanese cabinet decided to add South Korea to Appended Table 3 of the Export Trade Control Order. The order was promulgated on 30 June and took effect on 21 July 2023. From then, exporters could use general bulk licenses for goods and technology sent to South Korea. Those exports also left catch-all control, under which an exporter needs a license for unlisted goods that could be used for weapons. Japan's Ministry of Economy, Trade and Industry (METI) asked exporters to keep screening transactions, including end users and end uses.
Export Trade Control Order, Appended Table 3www.meti.go.jp
Gallium and germanium export licensing
Eight gallium items and six germanium items needed a license to leave China from August 2023.
China's Ministry of Commerce (MOFCOM) and the General Administration of Customs issued Announcement No. 23 of 2023 on national security grounds. It placed eight gallium-related and six germanium-related items under dual-use export licensing from 1 August 2023. Controlled items include gallium metal, gallium nitride, gallium arsenide, germanium metal, zone-refined germanium ingots and germanium tetrachloride. Exporters must apply to MOFCOM through provincial commerce departments and supply end-user and end-use certificates.
MOFCOM and GAC Announcement 2023 No. 23exportcontrol.mofcom.gov.cn
Japanese controls on 23 categories of chipmaking equipment
Japanese exporters needed a license to ship 23 more types of advanced chipmaking tools to any destination.
An amended ordinance from Japan's Ministry of Economy, Trade and Industry (METI) took effect on 23 July 2023, adding 23 types of advanced semiconductor manufacturing equipment to the export license list. METI had promulgated the ordinance on 23 May. The 23 items are tools for cleaning, deposition, annealing, lithography, etching and inspection. METI said the additions aim to prevent diversion to military use and supplement the Wassenaar Arrangement. The controls apply regardless of destination.
METI Ordinance No. 25 of 2023www.csis.org
Dutch license requirement takes effect for advanced immersion DUV
ASML needed Dutch licenses to ship its most advanced immersion DUV scanners, from the NXT:2000i on.
The Netherlands' national export control measure for advanced semiconductor manufacturing equipment entered into force on 1 September 2023. ASML said on 30 June 2023 that it would need Dutch licenses for all shipments of its most advanced immersion DUV systems, the TWINSCAN NXT:2000i and later models. The Dutch government would grant or deny the applications case by case. ASML said sales of its EUV systems were already restricted. It said it expected no material impact on its financial outlook for 2023.
European Chips Act enters into force
The EU set a goal of 20 percent of the global chip market in 2030 and put €3.3 billion of EU funds into chip research and pilot lines.
The European Chips Act entered into force on 21 September 2023, with the aim of doubling the EU's share of the global semiconductor market to 20 percent in 2030. Its first pillar, the Chips for Europe Initiative, has €3.3 billion of EU funds, which member states are expected to match. The money supports pilot production lines, a cloud-based design platform, competence centers, quantum chips and a Chips Fund for debt and equity financing. The second pillar creates a status for first-of-a-kind integrated production facilities and open EU foundries, which may receive state aid. The third sets up a mechanism for the European Commission and member states to monitor chip supply and, if needed, trigger a crisis stage.
Regulation (EU) 2023/1781ec.europa.eu
October 2023 update closes the A800 and H800 workaround
A density test caught the cut-down chips, and Chinese firms needed a license to buy them anywhere.
BIS replaced the interconnect-bandwidth test with a performance-density test, which divides a chip's computing power by its area. It split ECCN 3A090 into a controlled tier, 3A090.a, and a notification tier, 3A090.b, which together captured Nvidia's A800, H800, L40S and RTX 4090, a gaming card. BIS extended license requirements to companies headquartered in Macau or in Country Group D:5, the US list of arms-embargoed countries that includes China, wherever those companies are located. It also extended them to further destinations in Country Groups D:1, D:4 and D:5, to stop transshipment, the routing of chips through third countries. A companion rule tightened equipment controls. It also made certain immersion lithography tools for advanced chipmaking subject to US export rules if they held any American content at all, unless the country they were first exported from already controlled them. BIS separately added the Chinese GPU designers Biren and Moore Threads to the Entity List the same day. The rules were published on 25 October 2023 and took effect from 17 November.
88 FR 73458; 88 FR 73424 · 15 CFR 742.6(a)(6), (b)(10); 744.23www.federalregister.gov
Biren and Moore Threads added to the Entity List
On the day it tightened the AI chip rules, BIS listed the Chinese GPU designers Biren and Moore Threads.
On the same day it closed the A800 and H800 workaround, BIS added thirteen Chinese entities to the Entity List for developing advanced computing chips. They included Beijing Biren Technology and its affiliates and the three Moore Thread Intelligent Technology companies. A license is required for all items subject to the EAR, and applications are reviewed under a presumption of denial. BIS said advanced computing chips can provide artificial intelligence capabilities for weapons of mass destruction, advanced weapons systems and high-tech surveillance.
88 FR 71991 · 15 CFR 744.11www.govinfo.gov
Graphite export licensing
High-purity synthetic graphite and natural flake graphite needed a license to leave China from December 2023.
China's commerce ministry, MOFCOM, and the General Administration of Customs issued Announcement No. 39 of 2023, citing national security and interests. From 1 December 2023 two groups of graphite items needed a license to leave China. The first is synthetic graphite and its products with purity above 99.9 percent, flexural strength above 30 MPa and density above 1.73 grams per cubic centimeter. The second is natural flake graphite and its products, including spherical and expanded graphite. Exporters must apply to MOFCOM through provincial commerce departments and supply end-user and end-use certificates. The announcement lifted temporary controls on the other graphite items in a 2006 announcement, which it repealed.
MOFCOM and GAC Announcement 2023 No. 39www.mofcom.gov.cn
20246 moves
Dutch government partly revokes an ASML license for China
Before the end of 2023, the Dutch government partly withdrew a license it had already granted for two ASML immersion scanner models.
ASML said on 1 January 2024 that the Dutch government had recently partially revoked a license for the shipment of NXT:2050i and NXT:2100i immersion lithography systems in 2023. The revocation affected a small number of customers in China. ASML said it did not expect the revocation, or the latest US export rules, to have a material impact on its 2023 financial outlook.
Big Fund III capitalized at 344 billion yuan
China's third state chip fund was registered with 344 billion yuan, nearly a third of it from six state-owned banks.
The third phase of China's National Integrated Circuit Industry Investment Fund, known as the Big Fund, was registered on 24 May 2024 with 344 billion yuan of capital. Six state-owned banks planned to provide 33.14 percent of it, with Industrial and Commercial Bank of China, Agricultural Bank of China, Bank of China and China Construction Bank putting in 21.5 billion yuan each within 10 years. Industry sources expected silicon carbide and gallium nitride to be an investment focus. Phase I was registered in 2014 with 138.7 billion yuan and Phase II in 2019 with 204 billion yuan.
Dutch controls extended to more DUV immersion tools
The Dutch government took over from the United States the licensing of ASML's NXT:1970i and NXT:1980i immersion scanners.
On 6 September 2024 the Dutch government published an updated license requirement for exports of immersion DUV lithography equipment, in effect from 7 September. ASML said the change made the Dutch government, in place of the US government, the authority that licenses shipments of its TWINSCAN NXT:1970i and NXT:1980i immersion systems from the Netherlands. The requirement also covers specially designed parts, software and technology for these systems exported outside the EU. The Dutch requirement was already in place for the NXT:2000i and later immersion systems.
Staatscourant 2024, 29008www.sec.gov
Worldwide controls on gate-all-around, quantum and additive items
New worldwide license requirements came with an exception for countries that impose the same controls.
BIS added worldwide license requirements for gate-all-around transistor technology under ECCN 3E905, a set of quantum computing items, scanning electron microscopes under 3B903 and metal additive manufacturing (3D printing) equipment. BIS said the requirements were consistent with controls that several other governments had adopted. License Exception IEC (Implemented Export Controls) at §740.24 authorizes shipments to countries that have imposed equivalent controls. Exports to other countries still need a license.
89 FR 72926 · 15 CFR 742.6(a)(10); 742.4(a)(5); 740.24www.govinfo.gov
December 2024 equipment and HBM package
High bandwidth memory came under control for the first time, wherever it is made.
BIS controlled 24 additional types of semiconductor manufacturing equipment and three software tools. For the first time it also controlled high bandwidth memory (HBM), the stacked memory used in AI chips, under ECCN 3A090.c. The rule defines HBM as memory with a bandwidth density above 2 GB/s per square millimeter of package or stack area. BIS said every HBM stack then in production exceeded that line. The HBM control excludes packaged chips that combine HBM with logic and whose main function is processing. The chip controls may cover those instead. New foreign direct product rules extended the equipment and HBM controls to production outside the United States. But the equipment direct product rule largely exempts tools exported by firms located in Japan, the Netherlands and the 31 other countries listed in Supplement No. 4 to Part 742. Under License Exception HBM at §740.25, a US or Country Group A:5 exporter needs no license to ship stacks below 3.3 GB/s per square millimeter. The stacks must go directly to a packaging site for the designer that bought them. On the same day BIS added 140 entities in China, Japan, South Korea and Singapore to the Entity List. The rules were published on 5 December 2024 and took effect on 2 December. Compliance for the new ECCNs, the direct product rules and the DRAM definitions was required from 31 December.
89 FR 96790 · 15 CFR 742.6(a)(6); 740.25; 734.9(e)(3), (h), (k)www.federalregister.gov
Ban on gallium, germanium and antimony exports to the US
China moved from licensing to a ban on gallium, germanium and antimony exports to the US.
MOFCOM Notice No. 46 of 2024, issued the day after the US equipment package, banned exports of all dual-use items to US military users or for military uses. It said exports of gallium, germanium, antimony and superhard materials to the United States would in principle not be permitted. It also imposed stricter end-user and end-use checks on dual-use graphite sent to the United States. Unlike the 2023 measures, which set up licensing, this was a country-specific prohibition. The US Geological Survey estimated the gallium and germanium ban alone could cost the US economy about $3.4 billion of GDP.
MOFCOM Announcement 2024 No. 46cset.georgetown.edu
202528 moves
AI Diffusion Rule announced
The top band of AI chips needed a license everywhere, and closed AI model weights came under control.
The Framework for Artificial Intelligence Diffusion put a license requirement on the top band of AI chips, ECCNs 3A090.a and 4A090.a, for exports to or within any destination worldwide. It then eased that requirement through exceptions that differed by country. License Exception AIA allowed shipments to eighteen allies and the United States, the nineteen destinations listed in supplement no. 5 to part 740. License Exception LPP let each recipient almost everywhere else receive chips totaling up to 26.9 million TPP a year, about 1,700 H100-class GPUs. A license could take a country to a cumulative 790 million TPP through 2027, about 50,000 such GPUs. China, Russia and the rest of Country Group D:5 received neither exception. The rule also created Universal and National Validated End User authorizations for trusted data-center operators. Under ECCN 4E091, it controlled for the first time the model weights of closed frontier AI models, the trained numbers that make up each model. The rule took effect on 13 January 2025 and was published on 15 January, with a compliance date of 15 May. Nvidia and allied governments objected immediately.
90 FR 4544 · 15 CFR 740.27, 740.28, 740.29; 742.6; 748.15www.federalregister.gov
Dutch controls extended to measuring and inspection tools
The Dutch license requirement widened to measuring and inspection tools.
On 15 January 2025 the Dutch minister for foreign trade announced in the Government Gazette that the national license requirement for advanced semiconductor manufacturing equipment would cover further technologies from 1 April 2025. These included specific measuring and inspection equipment used in making advanced chips. The ministry described the addition as covering a very limited number of goods. It is the second amendment to the national measure since it took effect on 1 September 2023.
Staatscourant, 15 January 2025www.government.nl
Foundry due-diligence rule and Approved IC Designer status
Foundries and packagers had to check who an advanced chip was really for.
BIS required foundries and packaging houses to apply a due-diligence test before making advanced logic dies, the bare chips cut from a wafer. The rule presumes that such a die is a controlled 3A090.a chip. The presumption falls away if the designer is an approved or authorized IC designer, or if an approved outsourced assembly and test firm (OSAT) attests to the package's transistor count. Until 13 April 2026, designers headquartered in Taiwan or Country Groups A:1 and A:5 counted as authorized without applying. In April 2026 BIS extended that date to 31 December 2026.
90 FR 5298 · 15 CFR 744.23www.federalregister.gov
Tungsten, tellurium, bismuth, molybdenum and indium export licensing
Indium phosphide and items related to four other metals needed a license to leave China from February 2025.
China's commerce ministry, MOFCOM, and the General Administration of Customs put items related to five metals under export licensing, citing national security and non-proliferation obligations. The tungsten items include ammonium paratungstate, tungsten oxide and some tungsten carbide. The tellurium items include tellurium metal and cadmium telluride, cadmium zinc telluride and mercury cadmium telluride, among them substrates and epitaxial wafers. The bismuth and molybdenum items include bismuth metal and fine molybdenum powder. The indium items are indium phosphide, trimethylindium and triethylindium. Technology for producing the listed items is covered too. The controls took effect on publication, on 4 February 2025.
MOFCOM and GAC Announcement 2025 No. 10www.mofcom.gov.cn
TSMC raises US investment to $165 billion
Arizona is set to hold six TSMC fabs, two packaging plants and a research center.
At the White House, TSMC announced $100 billion of new US investment on top of the $65 billion already committed in Arizona, bringing the total to $165 billion. The plan covers three more fabs, two advanced packaging facilities and an R&D center, taking the Arizona campus to six fabs. TSMC said the expansion would support around 40,000 construction jobs over four years. TSMC said its first Arizona fab had been in volume production since late 2024.
Twelve more entities listed for AI and supercomputers
BIS shifted from listing chip designers to listing the labs and supercomputer centers that buy the chips.
BIS added twelve entities to the Entity List, eleven in China and one in Taiwan. It listed them for developing advanced AI, supercomputers and high-performance chips for Chinese end users tied to the military-industrial complex. Exporters need a license to ship them any item subject to the Export Administration Regulations (EAR), and applications face a presumption of denial or a policy of denial. Companion rules published the same day brought the day's total to about eighty entities, covering exascale supercomputing, hypersonics and quantum.
90 FR 14046 · 15 CFR 744.11www.govinfo.gov
Japan adds advanced chips and more chipmaking tools to its export controls
Japan's license list grew to cover chips such as GPUs with 6,000 TPP or more and at least 600 GB/s of chip-to-chip transfer, and more kinds of chipmaking tools.
Japan's Ministry of Economy, Trade and Industry (METI) added what it calls important and emerging technologies to its export license list, to prevent their diversion to military use. It also revised technical specifications, including some agreed in the Wassenaar Arrangement. The cabinet order was promulgated on 28 March 2025 and METI's ordinance on 3 April, and both took effect on 28 May. The list added chips with total processing performance (TPP), a measure of computing power, of 6,000 or more and at least 600 GB/s of data transfer to other chips. It also added computers that contain such chips. New chipmaking tools on the list include plasma doping ion implanters, imprint lithography tools and equipment for upgrading deep ultraviolet (DUV) immersion scanners. Annealing, deposition, etch and supercritical carbon dioxide cleaning tools, wafer defect inspection and overlay metrology tools, and extreme ultraviolet (EUV) masks were added as well. Exports of listed goods and technology need a license from Japan's minister of economy, trade and industry.
Cabinet Order No. 102 of 2025 and METI Ordinance No. 34 of 2025www.meti.go.jp
Export controls on seven medium and heavy rare earths
Seven medium and heavy rare earths, and magnets made with some of them, needed a license to leave China from April 2025.
China's commerce ministry, MOFCOM, and the General Administration of Customs issued Announcement No. 18 of 2025, citing national security and non-proliferation obligations. It put samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium under dual-use export licensing, together with their metals, alloys, oxides, compounds and the targets used to deposit them as thin films. Samarium-cobalt magnets and neodymium magnets that contain terbium or dysprosium are covered too. The controls took effect on the day of issuance, 4 April 2025.
MOFCOM and GAC Announcement 2025 No. 18english.mofcom.gov.cn
H20 and MI308 put under indefinite license requirement
The US required a license even for the China-compliant H20, costing Nvidia billions in charges and lost orders.
The US government told Nvidia that the H20 would indefinitely require a license for China, Hong Kong, Macau and Country Group D:5, the countries under a US arms embargo. Nvidia had designed the H20, a Hopper-generation chip, to stay within the October 2023 limits for China. The government's concern was that the chip could be diverted to a supercomputer. The restriction also covers any chip matching the H20's memory or interconnect bandwidth. Nvidia warned of up to $5.5 billion of charges for H20 inventory and purchase commitments, and in the end booked $4.5 billion in the quarter. It lost about $8 billion of orders in the next quarter. AMD disclosed a charge of up to $800 million on its MI308.
BIS stops enforcing the AI Diffusion Rule
The US stopped enforcing the rule and struck deals country by country, but every line of it stayed in the regulations.
Two days before the rule's compliance date, Commerce announced it would not enforce the AI Diffusion Rule and would issue a replacement rule. Nothing was withdrawn from the regulations. The Code of Federal Regulations still contains License Exceptions AIA, ACM and LPP at 15 CFR 740.27, 740.28 and 740.29, and the list of nineteen destinations in supplement no. 5 to part 740. It also still contains the worldwide license requirement at 742.6(a)(6)(iii)(A) and the 790 million TPP per-country allocation at 742.6(b)(10)(iii)(B). BIS said in July 2026 that it enforces the worldwide requirement only for destinations in Country Groups D:1, D:4 and D:5 that are not also in A:5 or A:6, for the United Arab Emirates, and for entities headquartered in Country Group D:5 or Macau or with an ultimate parent headquartered there. On 13 May 2025 BIS also issued three pieces of guidance. The first said that using Huawei Ascend 910B, 910C and 910D chips risks violating the EAR, because they were likely made with controlled US technology. The second warned that letting US AI chips train or run Chinese AI models could have consequences. The third set out how exporters should guard against diversion. The Ascend guidance originally said the chips were restricted "anywhere in the world", wording BIS softened after Chinese protests.
15 CFR 740.27, 740.28, 740.29; 742.6(a)(6)(iii)(A)www.bis.gov
US and UAE sign an AI agreement during the Gulf trip
The UAE pledged to build or finance US data centers as large as its own and to guard against diversion of US technology.
During President Trump's Gulf trip, the White House announced more than $200 billion of new US-UAE deals. It also announced an AI accord under which the UAE commits to build or finance US data centers at least as large and powerful as those it builds at home. The two governments separately announced a 5 gigawatt AI campus in Abu Dhabi led by G42, an Emirati AI company. Reports said the UAE could import the equivalent of roughly 500,000 Nvidia-class GPUs a year, about a fifth for G42 and the rest for large US cloud companies operating there. Saudi Arabia's new state AI company Humain signed agreements with Nvidia for several hundred thousand GPUs over five years and with AMD for a $10 billion program. The agreement also commits the UAE to align its national security rules with those of the United States, including protections to prevent the diversion of US-origin technology.
Design-software sales to China put under license by letter
One BIS letter required a license to sell US chip-design software to China, and another lifted the requirement about six weeks later.
On 23 May 2025 BIS sent a letter to Cadence, a US maker of chip-design software. It said a license was needed to export, reexport or transfer electronic design automation software and technology where a transaction involved China or Chinese military end users. On 2 July 2025 BIS told Cadence it had rescinded the requirement with immediate effect.
Cadence Form 8-K, 2 July 2025www.sec.gov
Taiwan adds Huawei and SMIC to its export control entity list
Taiwanese firms needed government approval to export anything to Huawei or SMIC.
Taiwan added Huawei Technologies and Semiconductor Manufacturing International Corp (SMIC) to its strategic high-tech commodities entity list. Taiwanese companies need government approval before exporting any products to companies on the list. The trade administration of Taiwan's economy ministry said it had updated the list on 10 June 2025 on the grounds of preventing arms proliferation and other national security considerations. It added 601 entities, including entities from Russia, Pakistan, Iran, Myanmar and China. The administration said manufacturers must comply with export control rules, fulfill their verification obligations and carefully assess transaction risks.
Strategic High-Tech Commodities Entity List, update of 10 June 2025www.reuters.com
H20 sales to China permitted again
The US agreed to license H20 sales, but Beijing discouraged Chinese buyers, so few chips shipped.
Nvidia said the US government had assured it that licenses for H20 sales to China would be granted, and that it hoped to start deliveries soon. AMD received the same assurance for the MI308. At the same time, Nvidia announced the RTX PRO 6000D, a chip built for the Chinese market. Chinese regulators then raised security concerns with domestic buyers in August. In September they told large firms to stop ordering the RTX PRO 6000D. In the same month, China's market regulator found that Nvidia had breached the conditions China set when it cleared Nvidia's purchase of the networking company Mellanox in 2020. Actual H20 shipments stayed small.
15 CFR 744.23blogs.nvidia.com
Malaysia requires permits for US-origin AI chips
Shipping US-origin high-performance AI chips out of or through Malaysia needed a permit from 14 July 2025.
Malaysia's Ministry of Investment, Trade and Industry (MITI) made all exports, transshipments and transits of high-performance AI chips of US origin subject to a Strategic Trade Permit, with immediate effect. It used section 12 of the Strategic Trade Act 2010, a catch-all provision that requires at least 30 days' notice before shipping an unlisted item that may be misused. MITI said the step would close regulatory gaps while Malaysia reviews adding these chips to its Strategic Items List. It said anyone found violating the act or related laws would face strict legal action.
Strategic Trade Act 2010, section 12www.miti.gov.my
A 15 percent revenue expectation attached to China licenses
Licenses to sell in China came with a demand for a share of revenue, but no rule or published legal basis backed it.
The US government granted licenses in August 2025 that allowed Nvidia to ship H20 products to certain China-based customers. Nvidia's annual report says US government officials expressed an expectation that the government would receive 15 percent or more of the revenue from licensed sales of the company's products. But, in the company's words, "the USG did not publish a regulation codifying such requirement". No such regulation has been published since. Nvidia generated about $60 million of H20 revenue under those licenses. Its filing for the quarter ended 26 July 2026 says Beijing restricted the purchases and that Nvidia was unable to sell its H20 inventory. Reports at the time said AMD had accepted the same terms for its MI308, but AMD has filed no comparable statement.
NVIDIA Form 10-K, FY2026www.sec.gov
US takes a 9.9 percent equity stake in Intel
The US government turned unpaid grants into Intel shares and became a part-owner of the company.
The US government bought 433.3 million Intel shares at $20.47 for $8.9 billion, about 9.9 percent of the company. It paid with $5.7 billion of unpaid CHIPS Act grants and $3.2 billion from the Secure Enclave program. Counting the $2.2 billion already disbursed, the deal accounted for $11.1 billion of Intel's federal awards. The stake is passive and carries no board seat. The government agreed to vote with Intel's board on most matters. The deal followed SoftBank's $2 billion investment in Intel and came before Nvidia agreed in September 2025 to buy a $5 billion stake.
Intel Form 8-K, 22 August 2025www.sec.gov
Validated End User status revoked for foreign fabs in China
Korean-owned fabs inside China may keep running but may not upgrade or grow.
BIS revoked the Validated End User authorizations that let three companies receive US equipment for their China fabs under a single general authorization. They were Samsung China Semiconductor, SK hynix Semiconductor (China) and Intel Semiconductor (Dalian), the NAND flash memory fab that SK hynix bought from Intel. The companies had 120 days after publication, to 31 December 2025, to obtain licenses. BIS said it would license the operation of existing fabs but would not approve capacity expansion or technology upgrades in China. It estimated the change would generate about 1,000 extra license applications a year. In December 2025 BIS granted SK hynix an annual license to ship approved US equipment to its China fabs during 2026.
Huawei announces the Ascend 950 series with its own HBM
Huawei designed its own high bandwidth memory (HBM) for its Ascend AI chips.
At the Huawei Connect conference in Shanghai, Eric Xu of Huawei set out a three-year roadmap for the company's Ascend AI chips. It has three new series, the Ascend 950, 960 and 970. The 950 comes in two versions with different memory. The Ascend 950PR is for the prefill stage of inference, when a model reads the prompt, and for recommendation systems. It uses HiBL 1.0, a Huawei-designed high bandwidth memory that the company presents as cheaper than HBM3E and HBM4E. Huawei said the 950PR would be available in the first quarter of 2026 as computing cards and in SuperPoD servers. The Ascend 950DT is for decode, when the model writes its answer, and for training. It uses HiZQ 2.0, another Huawei-designed HBM, with 144 GB of memory, 4 TB/s of memory bandwidth and 2 TB/s of interconnect bandwidth. Huawei said it built two kinds of memory because the inference stages have different needs.
Affiliates rule extends the Entity List to subsidiaries
Listed firms could no longer buy through unlisted subsidiaries, and the rule covered the Dutch chipmaker Nexperia.
BIS issued an interim final rule covering any entity that is 50 percent or more owned, directly or indirectly, by one or more Entity List or Military End User parties. The rule made such entities subject to the same license requirements as their listed owners, worldwide. It closed the long-standing gap in which listed firms bought through unlisted subsidiaries. Industry warned it could cover thousands of companies that were not on any list. It covered the Dutch chipmaker Nexperia, because Nexperia's owner, Wingtech, is on the Entity List. Beijing called it a serious escalation. BIS suspended the rule for a year on 10 November 2025.
90 FR 47201 · 15 CFR 744.11(a)(1); 744.21(a)(3); 744.8(a)(2)www.federalregister.gov
Dutch government invokes emergency powers over Nexperia
China restricted exports from Nexperia's sites in China, and the Dutch government suspended its order on 19 November 2025.
On 30 September 2025 the Dutch Minister of Economic Affairs invoked the Goods Availability Act over Nexperia, a chipmaker headquartered in Nijmegen, the first use of the act since 1952. The government said its concerns stemmed from actions attributed to the chief executive, involving the improper transfer of product assets, funds, technology and knowledge to a foreign entity. The order aimed to keep Nexperia's production capabilities available to Europe in an emergency. In separate proceedings, the Enterprise Chamber of the Amsterdam Court of Appeal suspended the chief executive and transferred all but one of the company's shares to a trustee. The Dutch government said China had imposed an export control measure on all Nexperia locations in China. On 19 November 2025 the Dutch government suspended its order. It cited constructive meetings with the Chinese authorities and the measures they had taken to ensure the supply of chips to Europe and the rest of the world.
Goods Availability Act 1952www.government.nl
Extraterritorial rare earth controls with a 0.1 percent rule
China claimed jurisdiction over foreign-made goods containing its rare earths, such as magnets and sputtering targets in chipmaking tools.
China's commerce ministry, MOFCOM, issued Notice No. 61 of 2025 and companion notices. Together they added holmium, erbium, thulium, europium and ytterbium to the controlled list. They put controls on rare earth mining, smelting, separation, magnet-making and recycling technology. They also asserted jurisdiction over foreign-made goods in which Chinese-origin controlled rare earths account for 0.1 percent or more of value. Exports for foreign military users face denial and those for advanced semiconductor and AI uses face case-by-case review. It was the first time China used its own version of the US foreign direct product rule, which claims control over foreign-made goods built with US technology. The 0.1 percent rule was due to take effect on 1 December 2025, but China suspended it on 7 November.
MOFCOM Announcement 2025 No. 61cset.georgetown.edu
China puts TechInsights on its Unreliable Entity List
Chinese organizations could no longer trade with TechInsights or its branches or send them data.
China's commerce ministry published a decision by its Unreliable Entity List working mechanism to add 14 foreign entities to the list. They include TechInsights Inc. and its branches, among them TechInsights Japan, TechInsights Korea, TechInsights Market Analysis and several Strategy Analytics companies. The listed entities may not take part in import or export activities related to China or make new investments there. Organizations and individuals in China may not trade or cooperate with them, and in particular may not send them data or sensitive information. The announcement cited the Foreign Trade Law, the National Security Law and the Anti-Foreign Sanctions Law and took effect on publication. The other entities named include Dedrone by Axon, AeroVironment, BAE Systems, Inc. and the Halifax International Security Forum.
Unreliable Entity List Working Mechanism Announcement 2025 No. 10www.mofcom.gov.cn
China suspends its October 2025 export controls for a year
China paused its widest rare earth controls, including the 0.1 percent rule, until 10 November 2026.
MOFCOM and the General Administration of Customs suspended six export control announcements issued in October 2025, from 7 November 2025 until 10 November 2026. They are MOFCOM and Customs Announcements 2025 Nos. 55, 56, 57 and 58 and MOFCOM Announcements 2025 Nos. 61 and 62. No. 61 is the rule that claimed jurisdiction over foreign goods with 0.1 percent or more Chinese rare earths by value.
MOFCOM and GAC Announcement 2025 No. 70www.mofcom.gov.cn
China suspends its ban on gallium, germanium and antimony exports to the US
China paused its December 2024 ban on mineral exports to the US until 27 November 2026.
MOFCOM suspended paragraph 2 of Announcement 2024 No. 46 from 9 November 2025 until 27 November 2026. That paragraph said exports to the United States of dual-use items related to gallium, germanium, antimony and superhard materials would in principle not be licensed. It also set stricter end-user and end-use checks on graphite exports to the United States.
MOFCOM Announcement 2025 No. 72www.mofcom.gov.cn
US suspends the affiliates rule for one year under the truce
Both sides suspended their broadest measures for a year, and China agreed to issue general licenses.
After the Trump-Xi meeting in Busan on 30 October 2025, BIS suspended the affiliates rule from 10 November 2025 until 9 November 2026. The same rule brings the affiliates rule back on 10 November 2026 unless the suspension is extended. China had suspended its own October 2025 export controls on 7 November and its ban on mineral exports to the United States on 9 November. China also agreed to issue general licenses, which cover repeated exports without a separate approval for each, for US end users and their suppliers.
90 FR 50857 · 15 CFR 744.11(a)(1)www.federalregister.gov
EU adds Dutch chip-tool controls to its own control list
Dutch national controls became EU-wide, with no change for ASML's own shipments.
The European Union added certain Dutch national controls to the EU Control List in November 2025, extending a license requirement for specific semiconductor manufacturing equipment to all member states. ASML said in its 2025 annual report that the requirement covers its DUV immersion lithography systems when they are exported outside the EU. It said the change made no difference to the company, because those products already required an export license from the Netherlands.
Trump clears H200 sales to China
China could buy the chip, but only after US testing and a 25 percent tariff.
President Trump announced that the United States would allow the H200 and similar products to be shipped to approved customers in China. BIS announced the implementing rule on 13 January 2026, and it took effect on publication on 15 January. It moved license applications for the Nvidia H200, the AMD MI325X and similar chips from a presumption of denial, under which they are normally refused, to case-by-case review. The applicant must show that the exports will not reduce the global semiconductor capacity available to US customers. It must also show that the Chinese purchaser has adopted export compliance procedures, including customer screening, and that the item has passed independent third-party testing in the United States. Nvidia's filings state that the licenses require each H200 to pass a US inspection before shipment. The filings say that, as a result, any H200 shipped under the program is subject to a 25 percent tariff on importation into the United States. Nvidia says it has been unable to pass the tariff on to customers.
BIS press release, 13 January 2026www.bis.gov
202610 moves
Section 232 proclamation puts a 25 percent tariff on advanced AI chips
A 25 percent tariff applies to advanced chips that pass through the United States for use elsewhere.
A presidential proclamation under Section 232, which lets the president restrict imports that threaten national security, imposed a 25 percent tariff from 12:01 a.m. on 15 January 2026. It covers a narrow set of advanced computing semiconductors, and products containing them, that pass through the United States but are not destined for US use. The covered chips fall in two bands. The first is chips of 14,000 to 17,500 total processing performance (TPP), a measure of computing power, with 4,500 to 5,000 GB/s of DRAM bandwidth. The second is chips of 20,800 to 21,100 TPP with 5,800 to 6,200 GB/s. These bands capture the Nvidia H200 and AMD MI325X. Nvidia's H200 licenses require each China-bound chip to pass an inspection in the United States before shipment, so every licensed H200 is imported first and pays the tariff. Eight use-based exemptions cover US data centers, R&D, start-ups, repairs, consumer and industrial uses and the public sector. The proclamation ordered a review of data-center chips by 1 July 2026 and signaled a second phase with higher rates and tariff relief for companies that invest in US chip production.
91 FR 2443 (Proclamation 11002)www.whitehouse.gov
H200-class chips move to case-by-case licensing for China
BIS began case-by-case licensing to China for a band of chips below the top tier, but not for Nvidia's newer Blackwell chips.
BIS announced the policy on 13 January 2026 and the rule took effect on publication, 15 January. It shifted license review from a presumption of denial to case-by-case review for exports of certain advanced computing chips from the United States to China and Macau. The covered chips have total processing performance below 21,000 and total DRAM bandwidth below 6,500 GB/s, the band covering the Nvidia H200 and AMD MI325X. Approval requires certifications of adequate US supply, independent third-party testing inside US customs territory, and know-your-customer and remote-access safeguards. Because the testing condition routes the chips through the United States, they also incur the 25 percent Section 232 tariff. Nvidia's newer Blackwell-class chips remain outside the policy. The rule changed only the China and Macau branch of the license policy, at 742.6(b)(10)(iii)(A)(1). It left the worldwide license requirement and the presumption of approval for the destinations in supplement no. 5 as they stood.
91 FR 1684 · 15 CFR 742.6(b)(10)(iii)www.federalregister.gov
US-Taiwan memorandum of understanding on investment
Taiwan won tariff relief on car parts, timber and aircraft components and pledged $250 billion of US investment.
The American Institute in Taiwan and the Taipei Economic and Cultural Representative Office, which serve as the two sides' unofficial embassies, signed a memorandum of understanding (MOU) on Taiwan-US investment. In it, the United States committed to modify certain Section 232 tariffs on Taiwanese goods. Commerce and the US Trade Representative implemented the tariff elements on 28 May 2026. They amended the tariff schedule for Taiwanese automobile parts, timber, lumber and wood derivative products, and removed derivative Section 232 steel, aluminum and copper tariffs from Taiwanese aircraft components. The two offices signed a broader Agreement on Reciprocal Trade on 12 February 2026, but it had not entered into force when the implementing notice was published. The notice records two commitments under the MOU. Taiwan will provide credit guarantees for up to $250 billion of corporate credit. Taiwanese semiconductor and technology firms will make $250 billion of new direct investment in the United States.
Applied Materials pays about $252 million for shipments to SMIC
Applied Materials paid twice what the shipments were worth, the second largest penalty in BIS history.
BIS announced a settlement of about $252 million with Applied Materials and its Korean subsidiary. The case concerned unlicensed reexports of ion implanters, chipmaking tools classified under ECCN 3B991, to SMIC after SMIC was added to the Entity List. The equipment was built in Massachusetts and routed through Korea. The shipments were worth about $126 million, so the penalty is twice the transaction value. That is the most the law allows, and the penalty is the second largest in BIS history. Applied Materials agreed to multiple compliance audits and annual certifications, and the employees responsible no longer work for the company.
15 CFR part 764www.bis.gov
Super Micro co-founder charged over AI servers diverted to China
Prosecutors allege that at least $510 million of AI servers reached China through false papers and layered transshipment.
Federal prosecutors in the Southern District of New York charged Super Micro co-founder Yih-Shyan "Wally" Liaw, Taiwan-based general manager Ruei-Tsang Chang and broker Ting-Wei Sun. They are charged with conspiring to violate the Export Control Reform Act, to smuggle goods and to defraud the United States. Prosecutors allege that a buyer purchased about $2.5 billion of servers from the manufacturer in 2024 and 2025 on false end-user records. They allege that at least $510 million of those servers were diverted to China between late April and mid-May 2025. The scheme allegedly relied on layered transshipment and on staged dummy servers to deceive auditors. Liaw resigned from the Super Micro board the next day and pleaded not guilty on 1 April 2026.
UAE moved to Country Group A:5
UAE government agencies, approved companies on a US list and eight named US AI firms can now receive advanced chips without a license.
BIS removed the United Arab Emirates from Country Groups D:3 and D:4, the US lists of countries of concern for chemical and biological weapons and for missiles. It added the UAE to A:5, a group of close US partners that face fewer export controls. The move made the UAE eligible for Strategic Trade Authorization and for license exceptions TMP, GOV, TSU, AVS and APR for chemical, biological and missile-technology controlled items. Advanced AI chips and the computers that contain them, under ECCNs 3A090.a and 4A090.a, still need a license. They need none when shipped to UAE government agencies, to approved commercial entities listed in a new Supplement No. 8, or to US-headquartered AI companies and their UAE subsidiaries. The rule names eight such companies: Amazon, Apple, Google, Meta, Microsoft, OpenAI, Oracle and xAI. The rule wrote into regulation the country-by-country approach that replaced the AI Diffusion Rule's country caps.
91 FR 43034 · 15 CFR 742.6(a)(6); 740www.federalregister.gov
India approves Semicon 2.0
India budgeted ₹1,27,500 crore for a second chip program after approving twelve plants under the first.
India's Union Cabinet approved Semicon 2.0, a program for the country's chip design and manufacturing industry with a budget of ₹1,27,500 crore. Its six pillars are chip design, machines and materials, new fabs, assembly and packaging units, research and development, and talent. The government said India's first fab is scheduled to be commissioned in 2028. Under Semicon 1.0, twelve manufacturing units had been approved with a cumulative investment of over ₹1.64 lakh crore. They include one silicon fab, one silicon carbide fab, a gallium nitride micro LED display fab and nine packaging units. Micron, Kaynes and CG Semi have started commercial production.
Proclamation 11052 sets a price floor and an extra duty on polysilicon imports
Imported silicon wafers face a price floor and an extra duty from December 2026, with relief for firms building US plants.
A presidential proclamation signed on 6 August 2026 set a minimum import price of $100 per kilogram for polysilicon ingots and wafers. Polysilicon is the purified silicon that chip and solar wafers are made from. The proclamation also set an extra 15 percent duty on imported ingots and other listed products made from polysilicon. Both measures start on 4 December 2026. Firms with Commerce-approved plans to build US polysilicon, ingot, wafer or solar cell plants, with construction starting by 20 January 2029, can import equipment and some of those products without the new duties. A Commerce rule published on 24 September 2026, meant to stop stockpiling before the duties start, lists doped single-crystal silicon wafers among the products it covers.
91 FR 51975 (Proclamation 11052)www.federalregister.gov
PRC restrictions leave the H200 licenses largely unused
Beijing restricted the sales, so Nvidia shipped a fraction of the licensed H200s and took a charge on unsold inventory.
Nvidia's quarterly filing for the period to 26 July 2026 records that the US government began granting licenses in February 2026 to ship small amounts of H200 to specific China-based customers. But, in the company's words, "such sales were restricted by the PRC government, and we have been unable to sell all the products for which we have licenses". Nvidia took a $0.4 billion charge in the first half of its fiscal 2027, the six months to 26 July 2026, for excess H200 inventory and purchase obligations. It shipped only a fraction of what the licenses allowed, and those shipments came to less than 1 percent of data-center revenue in the quarter. Customers headquartered in China, including Hong Kong, accounted for $7.9 billion of the quarter's $96.2 billion of revenue, against $4.0 billion a year earlier. Beijing has not published the measures behind its restrictions.
NVIDIA Form 10-Q, Q2 FY2027www.sec.gov
China hits Japanese dichlorosilane with duties of up to 99.2 percent
Chinese importers must post deposits of up to 99.2 percent on a Japanese gas that chip fabs use to lay down thin films.
China's commerce ministry, MOFCOM, issued a preliminary anti-dumping ruling against Japanese dichlorosilane, a specialty gas used for thin-film deposition in chipmaking. From 8 September 2026, importers must post deposits with Chinese customs at rates of 80.8 to 99.2 percent, pending a final ruling. The 99.2 percent rate applies to Shin-Etsu Chemical and all non-cooperating exporters. The investigation opened on 7 January 2026 after a complaint from the Chinese producer Tangshan Sanfu Electronic Materials. MOFCOM said the complaint's preliminary evidence showed import prices falling a cumulative 31 percent from 2022 to 2024. Japan protested the measure. The investigation is normally due to end by 7 January 2027 and can be extended by six months.
MOFCOM Announcement 2026 No. 37www.mofcom.gov.cn
China share of revenue, from company filings24 firms · FY2021 to FY2026
Each share links to the firm's filing for that year.The year it peakedThe firm changed how it counts China
| Firm | FY2021 | FY2022 | FY2023 | FY2024 | FY2025 | FY2026 |
|---|---|---|---|---|---|---|
| SCREEN HoldingsDeposition & Etch · Japan · counted by customer location | 30.7% | 26.2% | 20.5% | 39.4% | 42.4% | 38.4% |
| Tokyo ElectronDeposition & Etch · Japan · counted where it ships | 28.5% | 28.3% | 23.9% | 44.4% | 41.7% | 34.1% |
| Lam ResearchDeposition & Etch · United States · counted where it ships | 35.1% | 31.4% | 25.6% | 42.2% | 33.7% | 33.8% |
| DiscoAdvanced Packaging & OSAT · Japan · counted by customer location | 31.2% | 37.2% | 31.3% | 35.9% | 31.9% | 30.9% |
| KLAMetrology & Inspection · United States · counted where it ships | 26.5% | 28.9% | 27.3% | 42.8% | 33.3% | 29.8% |
| AdvantestTest · Japan · counted where it ships | Not filed for this year | Not filed for this year | Not filed for this year | 32.3% | 22.5% | 18.9% |
| HoyaPhotomasks · Japan · counted by customer location | 8.7% | 9.5% | 10.0% | 10.3% | 9.3% | 9.9% |
| NvidiaAI Accelerator Vendor · United States · counted where it is billed to FY2023, by headquarters from FY2024 | 23.3% | 26.4% | 21.4% | The firm counts China differently from this year. 20.2% | 19.2% | 9.1% |
| MicronMemory · United States · counted by headquarters | 8.9% | 10.8% | 14.0% | 12.1% | 7.1% | 6.3% |
| AMDAI Accelerator Vendor · United States · counted where it is billed | 24.9% | 22.1% | 15.1% | 24.2% | 22.4% | Not filed for this year |
| ASMLLithography · Netherlands · counted where it ships | 14.7% | 13.8% | 26.3% | 36.1% | 29.1% | Not filed for this year |
| Applied MaterialsDeposition & Etch · United States · counted where it ships | 32.7% | 28.1% | 27.3% | 37.2% | 30.1% | Not filed for this year |
| BE Semiconductor IndustriesAdvanced Packaging & OSAT · Netherlands · counted where it is billed | 37.6% | 25.9% | 35.5% | 33.6% | 35.0% | Not filed for this year |
| CadenceDesign & EDA · United States · counted where it is used | 12.7% | 14.6% | 16.6% | 12.3% | 12.8% | Not filed for this year |
| CamtekMetrology & Inspection · Israel · counted where it ships | 54.8% | 44.2% | 47.4% | 30.9% | 49.2% | Not filed for this year |
| EntegrisChemicals & Gases · United States · counted where it ships | 15.9% | 15.3% | 16.1% | 20.7% | 20.6% | Not filed for this year |
| NovaMetrology & Inspection · Israel · counted by customer location | 21% | 28% | 36% | 39% | 33% | Not filed for this year |
| Onto InnovationMetrology & Inspection · United States · counted where it ships | 19.1% | 25.0% | 16.8% | 11.8% | 7.0% | Not filed for this year |
| SK hynixMemory · South Korea · counted by own units | 36.6% | 27.4% | 30.9% | 23.5% | 19.7% | Not filed for this year |
| Samsung ElectronicsMemory · South Korea · counted by own units | 16.3% | 11.8% | 10.9% | 14.6% | 14.2% | Not filed for this year |
| SynopsysDesign & EDA · United States · counted by license seats | 13.4% | 16.8% | 16.1% | 16.1% | 11.5% | Not filed for this year |
| TSMCFoundry · Taiwan · counted by headquarters | 10.4% | 10.8% | 12.4% | 11.5% | 8.6% | Not filed for this year |
| TeradyneTest · United States · counted by customer location | 17.1% | 15.6% | 11.8% | 13.3% | 14.1% | Not filed for this year |
| Veeco InstrumentsDeposition & Etch · United States · counted by customer location | 18.2% | 19.1% | 32.7% | 35.6% | 27.4% | Not filed for this year |
The table covers 24 firms, each of which gives a figure for China in its own filings. Other firms are not shown, and some, such as Lasertec, AGC and Axcelis, give no China figure. Each share is computed from the revenue amounts the firm filed, except Nova's, which its filings give only as a rounded percentage. Firms count China differently, for example by where the goods ship, where they are billed, or where the customer is based. Fiscal years are labeled by the calendar year in which they end.