Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

The US Bureau of Industry and Security issued a final rule (RIN 0694-AK43, 91 FR 1684, signed 13 January 2026, effective 15 January 2026) revising the EAR license-review policy for exports of certain advanced-computing integrated circuits to end-users in China and Macau from a presumption of denial to case-by-case review. Eligibility is limited to commodities controlled under ECCN 3A090.a and 3A090.b with a Total Processing Performance (TPP) below 21,000 and total DRAM bandwidth below 6,500 GB/s — the band that covers NVIDIA H200 and AMD MI325X-equivalents and below. To qualify, exporters must certify (i) sufficiency of US supply such that the export will not delay domestic orders or divert foundry capacity, (ii) that aggregate TPP of advanced-node ICs exported to China or Macau will not exceed 50% of domestic shipments, (iii) compliance with end-use and end-user prohibitions, and (iv) prior performance review by a qualified independent third-party testing lab headquartered in the United States. The rule is the first material rollback of the October 2022 / October 2023 / December 2024 advanced-computing export-control architecture and operationalises the Trump-administration policy of trading H200-class chip access against Chinese cooperation on critical minerals, fentanyl precursors and Taiwan-strait restraint.

The US Bureau of Industry and Security amended the Export Administration Regulations to add 12 entities to the Entity List under the destinations of China (11) and Taiwan (1) via Final Rule 2025-05427 (90 FR 14046), companion to the larger 70-entity rule (2025-05426) published the same day. Targets fall in three clusters: (i) Beijing Academy of Artificial Intelligence and Beijing Innovation Wisdom Technology — added for acquiring US-origin items in support of China's military modernization, specifically developing large AI models and advanced computing chips for defense; (ii) the Inspur group — Inspur (Beijing) Electronic Information Industry, Inspur Electronic Information Industry, Inspur Electronic Information (Hong Kong), Inspur (HK) Electronics, Inspur Software, and Inspur Taiwan — added as subsidiaries contributing to supercomputers for military end use; and (iii) Henan Dingxin, Nettrix Information Industry, Suma Technology, and Suma-USI Electronics — added for involvement in the development of Chinese exascale supercomputers. License requirements are for all items subject to the EAR; review policy is presumption of denial for the AI cluster and policy of denial for the supercomputer clusters.

The US Bureau of Industry and Security issued its largest single export-control package targeting China's semiconductor industry on 2 December 2024, with three layered measures (final rules published in the Federal Register 5 December 2024). First, controls on high-bandwidth memory (HBM) above set performance thresholds — blocking the memory architecture that is foundational to AI training. Second, additions of 24 semiconductor manufacturing equipment item types to the Commerce Control List, covering deposition, etch, ion- implant, advanced packaging, and metrology categories. Third, Entity List designations for 140+ entities, the bulk Chinese semiconductor companies + equipment makers + investment vehicles, including major Chinese fab tooling firms. The package triggered MOFCOM's same-day-following retaliation (filed: 2024-12-03-china-mofcom-ge-ga-sb-export-ban-us).

The US Bureau of Industry and Security (BIS) final rule (89 FR 14385; FR Doc 2024-03969; Docket 240215-0050; RIN 0694-AJ54) added 93 entities under 95 entries to the Entity List, effective 23 February 2024, with destinations Russia (63), Turkey (16), China (8), UAE (4), Kyrgyzstan (2), India (1), and South Korea (1). The dominant rationale is enforcement of Russia-diversion controls: 46 Russian defense manufacturers are designated as military end users acquiring US-origin items for Russia's armed forces, five Chinese entities (including Dennex Enterprises Limited and Shenzhen Speed Industrial Materials Co.) are cited for facilitating diversion of controlled microelectronics to Russia, and 16 Turkish firms are cited as procurement hubs obtaining US-origin items of importance to Russia's war effort. Four UAE entities are designated for transshipment networks serving both Russia and Iran. All entities are subject to a presumption of denial for EAR-controlled items; Russian military end users are additionally subject to the Russia/Belarus FDP rule (15 CFR 734.9(g)).

On 25 October 2023 the Bureau of Industry and Security published an interim final rule (88 FR 73424; FR Doc 2023-23055) making substantive revisions to the October 7 2022 advanced-computing IFR, incorporating 43 public comments covering 78 topics. The rule replaced the prior TOPS-based performance metric with a new "Total Processing Performance" (TPP) / performance-density dual-threshold structure for ECCN 3A090, splitting the control into tiers 3A090.a (full licence requirement for highest-capability datacenter AI chips) and 3A090.b (new License Exception NAC with 25-day prior notification for the intermediate tier). Geographic scope was expanded from China-and-Macau to Country Groups D:1/D:4/D:5 to block diversion via third-country intermediaries and offshore datacenters.

The US Bureau of Industry and Security issued an interim final rule on 17 October 2023 that substantially expanded the advanced-computing and semiconductor manufacturing controls first imposed in October 2022. The rule closed the performance-threshold workaround that NVIDIA had used to ship China-specific A800/H800 GPUs, replacing it with a "performance density" metric and adding a new "Notified Advanced Computing" licence category. It expanded controls on chipmaking equipment (additional ECCNs covering deposition, etch, metrology), pulled 21 additional countries (mostly Middle East / Central Asia) into a regional licensing scheme to prevent transshipment, and added 13 Chinese entities to the Entity List including AI-chip designers.

The Bureau of Industry and Security (BIS) added 37 entities under 38 entries to the Entity List, effective March 2, 2023, spanning six destinations: China (28), Pakistan (4), Burma (3), Russia (1), Belarus (1), and Taiwan (1). The China tranche — the largest — targets entities supporting the People's Liberation Army's military modernization, including BGI Research and Forensic Genomics International (genomic surveillance/data risk), Inspur Group Co. Ltd. (cloud servers supplied to Chinese military), and Loongson Technology (domestic CPU developer). Three Burmese entities, including the Ministry of Transport and Communications, are designated for providing surveillance equipment enabling the military junta's tracking and targeting of civilians. Pakistani entities Abdul Razaq Asim, Add-On Technology, and Dynamic Engineers are added for contributing to Pakistan's ballistic missile programs; Russian DMT Electronics and Belarusian DMT Trading LLC for export-control evasion. All listed entities are subject to a license requirement for all items subject to the EAR, with the review policy being presumption of denial for the majority of Chinese entries.

The Bureau of Industry and Security (BIS) added 10 entities under 13 destination entries to the Entity List, effective February 24, 2023. The additions span three groups: (1) five Chinese entities operating in the commercial satellite and dual-use space sector — most notably Spacety Co., Ltd. and China HEAD Aerospace Technology Co., both suspected of supplying satellite imagery and space technology in support of the Russian military in Ukraine; (2) two Canadian procurement intermediaries (CPUNTO Inc. and Electronic Network Inc.) facilitating illicit acquisition of US-origin controlled items; and (3) three Russian defense-industrial procurement companies supplying the Russian military. All listed entities are subject to a license requirement for all EAR-subject items with a policy of denial, except EAR99 food and medicine which receive case-by-case review.

The US Bureau of Industry and Security imposed broad new controls on the export of advanced computing chips, chipmaking equipment, and US-person services supporting Chinese semiconductor fabrication. The October 7 2022 rule blocked supply of GPUs above set performance thresholds (initially 600 GB/s interconnect / 4800 TOPS) to China and added end-use restrictions on manufacturing tools used in advanced (≤14/16 nm logic, ≤18 nm DRAM, ≤128-layer NAND) facilities, with a foreign direct product rule extending coverage globally.

The U.S. Bureau of Industry and Security (BIS) added seven Chinese entities — under seven entries — to the Entity List, effective August 24, 2022, for acquiring or attempting to acquire U.S.-origin items in support of China's military modernization efforts. The entities span China's state-owned aerospace, space-technology, electronics, and control-systems research institutes. All seven entries carry a license requirement covering all items subject to the EAR, with a presumption-of-denial review policy.

The Bureau of Industry and Security added 77 entities (under 78 entries) to the Entity List via a December 22, 2020 final rule (FR Doc 2020-28031). The headline designation is Semiconductor Manufacturing International Corporation (SMIC) — China's largest contract chipmaker — for activities related to military-civil fusion (MCF), with a presumption of denial applied to all items uniquely required to produce chips at advanced nodes of 10 nanometers or below. The batch also covers entities that supported PRC militarisation of artificial islands in the South China Sea and entities implicated in human rights abuses against Uyghurs and other minorities in Xinjiang.