BIS Entity List: Seven Chinese Supercomputing Entities

Mechanism

BIS amended the Export Administration Regulations (EAR) to add seven Chinese entities to the Entity List under 15 C.F.R. Part 744. All seven received an EAR license requirement for all items subject to the EAR (no de minimis threshold), with a license review policy of presumption of denial. The designation was made by the End-User Review Committee (ERC) on the basis that these parties have been involved in activities contrary to U.S. national security and foreign policy interests.

The seven entities: 1. National Supercomputing Center Jinan — operates supercomputing infrastructure for military-linked research 2. National Supercomputing Center Shenzhen — part of China's national HPC grid, linked to defense applications 3. National Supercomputing Center Wuxi — home of the Sunway TaihuLight system (formerly world's fastest), supported via Sunway Microelectronics processors 4. National Supercomputer Center Zhengzhou — additional node in China's military-facing HPC network 5. Shanghai High-Performance Integrated Circuit Design Center — IC design center contributing to domestic chip development for supercomputing 6. Sunway Microelectronics — fabless chip company producing the Sunway processor family used in the TaihuLight supercomputer; directly linked to NUDT and PLA procurement 7. Tianjin Phytium Information Technology — fabless semiconductor company producing Phytium ARM-compatible processors; supplied to PLA procurement channels and military supercomputing clusters

Downstream implications

• All U.S.-origin semiconductor equipment, EDA software, and advanced chips are now subject to

a presumption-of-denial license requirement when destined for any of the seven entities or their subsidiaries.

• Sunway and Phytium are the two chip designers most critical to China's indigenous HPC

capability; cutting off their access to U.S.-content IP and equipment degrades the refresh cycle for the next generation of China's exascale systems.

• The action preceded the October 2022 advanced chip controls (ECCN 3A090 / HBM) by 18 months

and served as the entity-level complement to the later technology-level controls.

• Tianjin Phytium subsequently appeared in multiple subsequent BIS entity list sweeps

(carried-over listings confirmed in later rulemakings).

Open questions

• Whether the four National Supercomputing Centers were ultimately successful in obtaining chips

via third-country intermediaries before subsequent controls closed that channel.

• Whether Sunway's next-generation processor (SW52010) was completed before the designation

materially constrained design-tool access.