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Last amendment: Commodity-list expansion adding 18 sensitive-technology items: advanced 3D printers, advanced semiconductor manufacturing equipment, electron microscopes and quantum-computing hardware. Distinct from entity-list amendments — extends the controlled-items perimeter. on 2025-11-18.
Taiwan's SHTC regime is the statutory equivalent of the US BIS Entity List. Under Article 13 of Taiwan's Foreign Trade Act, MOEA-ITA maintains:
requires a case-by-case government licence.
The 10 June 2025 amendment was announced via MOEA-ITA press release on 15 June 2025 and added 601 entities in a single tranche — the largest single expansion in the regime's history and the first to name Huawei and SMIC explicitly. The legal effect is that any Taiwanese exporter shipping any SHTC-listed item, directly or via third-party transhipment, to a listed entity must apply for a pre-export licence, with the presumption of denial for advanced-node semiconductor manufacturing equipment, AI-relevant compute, and any item ECCN-equivalent to US 3A090 / 4A090.
The 18 September 2025 amendment added a further 279 entities (with 7 removals); the 18 November 2025 amendment expanded the commodity-list itself by 18 items covering advanced 3D printing, semiconductor manufacturing equipment, electron microscopes and quantum-computing hardware — closing several non-Entity-List loopholes around generic dual-use machinery.
Taiwan was, until June 2025, the major chip-supply jurisdiction without an explicit Huawei / SMIC export-control instrument. The trilateral US-Japan-Netherlands chip-equipment perimeter (see theme trilateral-chip-equipment-perimeter) closed Tokyo, Amsterdam and Washington but left Taipei outside the formal architecture — a non-trivial gap given that TSMC, UMC, ASE and KYEC together represent the bulk of foundry, packaging and test capacity downstream of US/Japanese/Dutch fab tooling. The June 2025 SHTC amendment closes the Taiwan side of the perimeter, materially narrowing the legal pathway by which PRC-listed entities can source advanced-node wafers, packaging or test services via Taiwan-based suppliers.
Severity is set at 5 (highest tier) on three grounds:
1. Scale — 601 entities in one tranche, with two follow-on amendments adding another 279 entities and 18 commodity categories, against a base of ~10,000 entities pre-June 2025. 2. Choke-point geography — Taiwan is the global concentration point for advanced-node fab and OSAT (outsourced semi-assembly & test) capacity; bringing it into the export-control architecture closes a sanctions- circumvention vector that had been active since 2022. 3. First standalone Taiwan export-control action in IPTM register — prior Taiwan filing (2023-01-07 Chips Act Article 10-2) is an R&D incentive, not a control instrument; this is the first time MOEA-ITA has used the SHTC apparatus for headline geoeconomic effect.
SMIC. TSMC had already self-imposed a Huawei cut-off post-2020 US FDP rule, but the new instrument formalises Taipei's enforcement posture and reduces the legal ambiguity around third-party transhipment via shell distributors.
pathways (cross-strait trade frictions, possible China-side counter- controls on Taiwan suppliers' upstream inputs).
marginally extends the addressable-market squeeze on PRC fab capacity build-out, modestly supportive of non-PRC fab capex.
near-term advanced-node roadmap depends increasingly on indigenously- developed equipment as the Taiwan / US / Japan / Netherlands perimeter consolidates.
Pakistan vs Myanmar) — not disclosed in MOEA press release.
trade.gov.tw press-release index requires manual traversal to pin down.
destined for listed entities (analogous to BIS Entity List enforcement reports). Will be the leading indicator of whether the regime tightens or relaxes in practice.
Taiwan-domiciled suppliers' rare-earth or upstream-mineral access.