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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.
BIS did not issue a public rule or Federal Register notice for this action — it was communicated as individual letters to the three dominant EDA vendors (Cadence, Synopsys, Siemens EDA, which together control the large majority of global chip-design software). The letters imposed a license requirement on exports, re-exports, or in-country transfers of EDA software/technology under ECCNs 3D991 and 3E991 whenever a Chinese party or Chinese "military end user" was involved — effectively covering all commercial EDA sales into China, since BIS did not provide a practical mechanism to distinguish civilian from military end users at scale. The only public record of the action is the issuers' own securities filings: Cadence's Form 8-K (Item 8.01, 23 May 2025) quotes the BIS letter verbatim, and Synopsys separately withdrew its FY2025 guidance citing the same restriction.
The measure sits alongside the broader May 2025 BIS guidance warning that use of Huawei Ascend chips anywhere in the world violates US export controls, and followed the April 2025 informal-letter restrictions BIS placed on Nvidia's H20 and AMD's MI308 chips to China — all part of a pattern of using company-directed letters rather than published rules to tighten the semiconductor chokepoint on China outside the normal notice-and-comment process.
development; a license requirement here reaches further upstream in the chokepoint chain than equipment or IP-core controls.
outside analysts to track — no Federal Register docket exists — and it was discoverable only via the vendors' own securities disclosures, an unusual transparency gap for a trade-control action of this scale.
shows BIS treating EDA license leverage as a negotiating chip rather than a fixed national-security control — a pattern worth tracking if tensions resurface.
(via a further informal letter) without a published rule, and under what trigger it might do so again.
Siemens EDA during the ~6-week window the restriction was in force.