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Three layers stacked into a single rule:
1. Item-level controls. A new ECCN scheme covering high-end GPUs (NVIDIA A100/H100 class and equivalents), advanced HBM, and chipmaking tools (etch, deposition, lithography, metrology) used at the leading edge. 2. End-use controls. Even non-listed items become licensable if they're "used in" or "destined for" a Chinese facility producing advanced logic, DRAM, or NAND at the specified nodes — with presumption of denial for advanced facilities, case-by-case for others. 3. US-persons rule. US persons are barred from supporting the development or production of these chips and tools at covered Chinese facilities without a licence.
The Foreign Direct Product (FDP) rule was extended so that any foreign-made chip incorporating US technology — even chips designed by Chinese firms but fabricated abroad — falls in scope.
This is the foundational measure that all subsequent US chip controls (Oct 2023 expansion, Sep 2024 quantum/biotech additions, Dec 2024 HBM additions) build on. It severed the supply of training-grade AI chips to China and forced a multi-year scramble of workarounds (NVIDIA H800/H20 variants), domestic substitution (Huawei Ascend), and parallel-supply-chain construction.
between US Validated End User status (with licence relief at their China fabs) and exiting Chinese expansion entirely; both took conditional VEU paths, then renegotiated repeatedly.
export-control negotiations that culminated in 2023 Dutch controls (filed separately).
tooling and refocused on mature nodes — meaningful headwind to MCHI's tech-heavy weighting.
thresholds further and closed the H800 workaround. Is the cumulative surface-area-affected severity now ≥5, or is October 2022 still the structural break?
equipment trade was ~$8B in 2022; that lower-bounds the floor at severity 5 even before downstream effects.