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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.
The October 17, 2023 BIS rule (FR Doc 2023-22873 / 88 FR 71478) revised the VEU list for China as part of the broader advanced chip-controls expansion. As part of that package, BIS updated the VEU terms for the two Korean-owned fabs operating in China — Samsung China Semiconductor (Xi'an; NAND flash) and SK hynix Semiconductor (Wuxi; DRAM).
This November 8 correction addresses two specific drafting errors from that rule:
1. SK Hynix eligible-items description: A word was inadvertently omitted from the description of items eligible for export to SK hynix Semiconductor (China) Ltd. The correction restores the intended scope.
2. SK hynix Semiconductor (Wuxi) removal: The October 2023 rule failed to remove the standalone VEU entry for SK hynix Semiconductor (Wuxi) after that entity merged into SK hynix Semiconductor (China) Ltd. The correction removes the now-defunct Wuxi entry, consolidating both under the single China entity.
Korean semiconductor manufacturers operating legacy fabs in China received VEU authorisations as part of the October 2022 and October 2023 export-control expansions, allowing them to continue receiving controlled equipment without individual export licences (subject to enhanced oversight conditions and one-year rolling authorization periods). These VEU authorisations were a key diplomatic accommodation for Seoul, balancing US chip-controls objectives against South Korea's significant industrial interests in China.
The Wuxi site (SK Hynix's primary China DRAM facility) and the Xi'an site (Samsung's primary China NAND facility) collectively represent a substantial share of both companies' legacy-node capacity. The legal consolidation of SK hynix Semiconductor (Wuxi) into SK hynix Semiconductor (China) Ltd. is an administrative step with no operational significance for production capacity or export-control compliance status.
(see 2025-09-02-us-bis-veu-revocation-china-fabs)
regulatory questions or compliance requirements