US Chip Export Controls on China, Explained

Since October 2022 the United States has limited which advanced chips and chipmaking tools can be shipped to China, and to which Chinese companies. The rules are written by the Commerce Department’s Bureau of Industry and Security (BIS) in the Export Administration Regulations, and they have been rewritten many times since. China has answered with export controls of its own on minerals used in chips, and with steps aimed at individual US companies.

This explainer sets out what the rules cover as of October 26, 2026, how they got here, and what the companies affected have said in their filings. It describes the rules; it takes no position on them.

What do the US rules control?

Three kinds of items, plus rules about who may receive them:

• Advanced AI chips. The control list entry 3A090 covers chips by a performance measure called total processing performance (TPP), defined as “2 × ‘MacTOPS’ × ‘bit length of the operation’.” A chip is covered if its TPP is 4,800 or more, or 1,600 or more with a “performance density” of 5.92 or more. Computers that contain such chips are covered too (4A090).
• Chipmaking equipment. Certain tools for making advanced chips are controlled under category 3B of the control list, in entries such as 3B001.
• High-bandwidth memory (HBM). Since the December 2024 rule, 3A090.c covers “high bandwidth memory (HBM) having a ‘memory bandwidth density’ greater than 2 gigabytes per second per square millimeter.”

Three mechanisms extend the reach of those lists:

• Foreign direct product (FDP) rules apply US controls to some items made outside the US with US technology or tools. The regulations now include an advanced computing FDP rule and a semiconductor manufacturing equipment FDP rule.
• The Entity List names companies that need a license to receive items subject to the regulations. A December 2024 rule added 140 entities at once.
• “US persons” rules require a license for Americans to support the development or production of advanced-node chips in China, including Macau, and some other countries.

How did the rules develop?

Date	What happened	Source
Oct 7, 2022	First controls on advanced computing chips and chipmaking items, wider FDP reach for 28 listed entities, limits on US persons	87 FR 62186
Oct 17, 2023	Updated chip and equipment rules, effective November 17, 2023	88 FR 73458, 88 FR 73424
Dec 2, 2024	HBM controls, more equipment, new FDP rules; 140 entities added to the Entity List	89 FR 96790, 89 FR 96830
Jan 15, 2025	“AI Diffusion” rule with country tiers for AI chips	90 FR 4544
Apr 9, 2025	License required for Nvidia’s H20 chip for China, by letter to Nvidia	Nvidia 10-Q
May 13, 2025	BIS said it would rescind the AI Diffusion rule and not enforce it	BIS release
Aug 2025	Licenses for some H20 shipments	Nvidia 10-K
Aug 29, 2025	Validated end-user status removed for Samsung’s, SK hynix’s and Intel’s former fabs in China, effective December 31, 2025	90 FR 42321
Sep 29, 2025	Entity List extended to companies at least 50% owned by listed entities (“affiliates rule”)	90 FR 47201
Nov 12, 2025	Affiliates rule suspended until November 9, 2026	90 FR 50857
Jan 15, 2026	Case-by-case license review for chips such as Nvidia’s H200 and AMD’s MI325X, with conditions	91 FR 1684

Two details show how unsettled the picture has been. The AI Diffusion rule was never formally withdrawn: BIS said in May 2025 it would publish a rescission and told its enforcement officials “not to enforce,” but the text is still in the regulations as of October 2026. And for the H20 licenses in August 2025, Nvidia’s annual report says US officials “expressed an expectation that the USG will receive 15% or more” of the revenue, but “the USG did not publish a regulation.”

What changed in January 2026?

The January 15, 2026 rule moved license reviews for China “from a presumption of denial to a case-by-case review” for chips with a TPP “less than 21,000” and DRAM bandwidth “less than 6,500 GB/s, such as the NVIDIA H200 or AMD MI325X.” It set conditions: shipments to China and Macau of “no more than 50%” of the volume shipped to US customers, and testing by a third party in the US.

The opening did not lead to large sales. Nvidia said its government granted a license for “small amounts of H200” in February 2026. Its quarterly report of August 26, 2026 said such sales “were restricted by the PRC government,” that it took a US$0.4 billion charge associated with the H200, and that these shipments were less than 1% of its data center revenue.

What has it meant for US chip companies?

The companies’ own filings put numbers on it.

⤢

• Nvidia recorded a US$4.5 billion charge in the first quarter of fiscal 2026 related to the H20, when the April 2025 license requirement took effect. By the location of customers’ headquarters, China including Hong Kong was 9.1% of its fiscal 2026 revenue, down from 19.2% a year earlier. Nvidia’s fiscal years end in late January; its 2026 report changed the basis of its geographic figures and restated earlier years.
• AMD said it recorded about US$800 million of charges related to its MI308 chip and later reversed about US$360 million.
• Equipment makers still earned a large share of their revenue in China, according to their latest annual reports: about 30% of Applied Materials’ fiscal 2025 revenue, about 34% of Lam Research’s fiscal 2026 revenue and 29.8% of KLA’s. In February 2026 BIS said Applied Materials agreed to pay about US$252 million over illegal equipment exports, the “second-highest penalty ever” in its words.

What has it meant for Asian chipmakers?

The rules reach Asian companies in two ways: through their factories in China, and through the FDP rules on what they may ship there.

• Samsung and SK hynix. Their memory fabs in China had validated end-user (VEU) status, which let US equipment go to them without separate licenses. That status ended on December 31, 2025. BIS said it “intends to grant export license applications to allow former VEU participants to operate their existing fabs,” but “does not intend to grant licenses to expand capacity or upgrade technology.”
• TSMC. Its 2025 annual report says that although its VEU authorization for its Nanjing fab expired in December 2025, the Commerce Department “has granted TSMC Nanjing… an annual export license.”
• HBM. The December 2024 HBM control covers the memory that SK hynix, Samsung and Micron make for AI chips. Who Makes What in Memory explains HBM and its makers.

Other governments have added rules of their own. The Netherlands has required licenses for some deep ultraviolet (DUV) lithography equipment since September 1, 2023, widened them on September 7, 2024, and added certain measuring and inspection equipment from April 1, 2025. Taiwan added 601 entities to its own strategic high-tech list in June 2025, including Huawei and SMIC.

How has China responded?

China’s Ministry of Commerce (MOFCOM) has put export controls on minerals and materials used in chips and electronics, and other agencies have acted against US companies:

Date	Measure	Status on October 26, 2026
Jul 3, 2023	Gallium and germanium exports need a license	No suspension found
May 21, 2023	Cyberspace regulator says critical infrastructure operators may not buy Micron products	In force, per Micron’s 2026 annual report
Oct 20, 2023	Graphite export controls	No suspension found
Aug 15, 2024	Antimony export controls	No suspension found
Dec 3, 2024	In principle no licenses for gallium, germanium, antimony and superhard materials to the US	Suspended until November 27, 2026, except for US military users
Apr 4, 2025	Controls on seven medium and heavy rare earths	No suspension found
Sep 13, 2025	Anti-dumping investigation into US analog chips	No ruling found
Sep 15, 2025	Market regulator says a preliminary investigation found Nvidia violated China’s anti-monopoly law	No outcome found
Oct 9, 2025	Wider rare earth and related controls	Suspended until November 10, 2026

As of October 26, 2026, no extension of any of the three suspensions (the US affiliates rule and China’s two measures) had been published.

Which dates come next?

• November 9, 2026: the US affiliates rule’s suspension ends “absent a future extension.”
• November 10, 2026: China’s suspension of its October 2025 rare earth measures ends.
• November 27, 2026: China’s suspension of its ban on gallium, germanium, antimony and superhard material exports to the US ends.

Each could be extended, allowed to lapse or replaced. For how the companies involved make chips, and which ones design rather than manufacture, see Foundry, Fabless and IDM. For the packaging behind AI accelerators, see What Is CoWoS?.