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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.
Three separately-published but jointly-issued rules:
1. Advanced Computing Items (ACI) update. - Drops the bandwidth-only test (which NVIDIA's A800/H800 had been engineered around) in favour of a "Total Processing Performance" metric calibrated to per-chip throughput. - Adds a "performance density" cut-off so that smaller dies hitting the same compute density as covered parts are also captured. - Creates Notified Advanced Computing (NAC) — a new, intermediate category that allows shipment to non-China destinations after a 25-business-day notification, but requires a presumption-of-denial licence for China. - Pulls Macau, the broader Middle East, and several Central Asian states into a regional licensing scheme to plug transshipment.
2. Semiconductor Manufacturing Items (SME) update. - Adds new ECCNs covering deposition (specifically Aixtron- style MOCVD tools), etch, metrology, and ion-implantation systems used at advanced nodes. - Strengthens the US-persons rule and the Foreign Direct Product (FDP) rule scope.
3. Entity List additions. 13 Chinese entities added, including Moore Threads and Biren Technology — the two highest-profile domestic AI-chip designers — plus several subsidiaries.
This is the rule that effectively shut down the "tweak it for the China market" path NVIDIA had been using since Oct 2022. Combined with the SME tooling additions and the regional expansion, the cumulative export-control surface area on US→China advanced compute and tooling is the highest it has been since the Cold War. NVIDIA confirmed in its Q3 FY24 calls that affected Chinese revenue would "decline significantly" near-term; the company subsequently engineered the H20 (a much more constrained part) for the Chinese market.
Severity 5 because the rule is meaningfully broader than the 2022 baseline AND because it closed the most economically- significant workaround.
reported a substantial near-term revenue impact; the H20 workaround re-emerged in mid-2024 then was further constrained in 2025.
all faced incremental China-fab licensing friction; ASML's 2024 disclosure of restricted China revenue grew accordingly.
alternatives (Huawei Ascend, Cambricon) and SMIC 7nm capacity.
(separate filing) and the Dec-2024 HBM additions.
trade is a small share of total bilateral trade, but >>25% of the relevant HS code (9030.84 / 8542 advanced ICs). Need to decide which slice the quant scoring uses.
around again) may warrant filing each iteration as a distinct action; current practice is to file the BIS rule and let the industry-response narrative live in the body.