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Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
This final rule implements a three-part enforcement action under the Export Administration Regulations (EAR), consolidating 36 new Entity List additions across two major clusters and one Russia-oriented designation revision.
The dominant cluster covers nine Cambricon entities and three memory/equipment firms:
Cambricon (688256.SS) and eight subsidiaries — China's leading AI chip designer (Kunlun AI, neural processing units) receives the Footnote 4 Foreign Direct Product (FDP) designation. The FDP rule means that foreign-produced items that are the direct product of US-origin technology or software, or produced by a fab using US equipment, require a US export licence to reach any Cambricon entity anywhere in the world. The Footnote 4 addition effectively globalises the restriction beyond what a standard entity-list entry achieves, because it captures Cambricon-destined chips manufactured in Taiwan or elsewhere using US semiconductor equipment.
Yangtze Memory Technologies Co., Ltd. (YMTC) — China's largest NAND flash memory manufacturer — is added on diversion-risk grounds (risk of supplying Huawei and other sanctioned entities). Simultaneously, YMTC is removed from the Unverified List as a conforming change, since BIS policy prohibits dual listing. YMTC's Japan subsidiary (Yangtze Memory Technologies (Japan) Inc.) is also added, closing the offshore procurement loop.
Shanghai Micro Electronics Equipment (SMEE) — China's sole domestic producer of lithography equipment — is listed for its role in supporting China's drive to indigenise chip manufacturing, a direct response to the October 2022 advanced-computing controls (see responds_to). Alongside PXW Semiconductor Manufactory and Shanghai Integrated Circuit Research and Development Center, this forms a mini-cluster targeting China's domestic semiconductor supply chain.
Thirteen entities are added on military-modernisation or human-rights grounds without the FDP footnote:
advanced aerospace composites for military platforms
automation design
entities
military programs
fusion AI and military information systems
The China Electronics Technology Group Corporation 13th Research Institute (CETC 13) and its 12 Hebei-based microelectronics subsidiaries (Bowei Integrated Circuits, Tonghui Electronics, MT Microsystems, North China Integrated Circuit Corporation, and others) are revised to add Footnote 3 — the Russian military end-user designation under 15 CFR §744.21. This activates the Russia/Belarus FDP rule (§734.9(g)) and imposes a blanket denial policy for all EAR items, replacing the prior case-by-case review. Two existing entries (HSJ Electronics, Tenco Technology) are also revised to bring them into conformity with the updated CETC 13 structure.
implicitly targeted YMTC-grade 3D NAND; formal listing closes the UVL loophole and triggers licence requirements for all US and foreign (FDP-covered) NAND flash sales to YMTC.
US→China transactions. Any TSMC or Samsung foundry run producing chips destined for Cambricon becomes subject to US licence requirements.
generations) but strategically significant: it forecloses US-origin inputs into China's indigenisation of lithography.
military supply chains. The blanket denial policy removes licensing flexibility that had previously allowed EAR99 food/medicine exceptions.
and whether its NAND chips remain commercially competitive in the near term.
taking Cambricon orders; SMIC is the fallback at reduced process node).
investment by cutting off the US inputs SMEE itself relies on.