Export controls do not create a single, permanent ban on China’s access to AI hardware. They create a moving set of performance thresholds, licenses, entity restrictions, end-use rules and anti-diversion requirements that can block a shipment, delay it, force a redesign or permit a sale under conditions. The controls target both the finished system—advanced accelerators, high-bandwidth memory (HBM) and related components—and the factories and software needed to make them. Lithography licenses matter because a company may possess a chip design yet lack the tools, process technology and servicing needed to manufacture it at scale.
What export controls actually cover
The United States and allied governments regulate more than a chip’s model number. The control perimeter reaches the computing device, key memory, semiconductor-manufacturing equipment, design and process software, technical support and the organizations that receive or operate those items.
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Advanced AI chips and HBM
U.S. rules first focus on the performance characteristics that make a processor useful for large-scale artificial intelligence. The October 2022 and October 2023 rules, clarified by the Bureau of Industry and Security (BIS) on April 4, 2024, restrict the People’s Republic of China’s ability to purchase advanced computing chips and to manufacture advanced chips considered critical to military advantage. A chip can therefore be controlled because of its measured performance, the way its components are connected, or the system in which it is installed.
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High-bandwidth memory is controlled alongside accelerators because modern AI systems depend on moving huge volumes of data between memory and compute. A permitted-looking processor paired with restricted HBM can still be an export-control problem. The December 2, 2024 BIS package added HBM controls and expanded the list of covered manufacturing technologies.
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Manufacturing equipment and software
The December 2, 2024 package covered 24 types of semiconductor-manufacturing equipment and three categories of software tools, and added 140 PRC entities to the Entity List. The equipment categories include etch, deposition, lithography, ion implantation, annealing, metrology, inspection and cleaning. These steps determine whether a design can become a reliable, high-yield wafer rather than merely a laboratory demonstration.
Controls on equipment close a loophole that would remain if finished accelerators were restricted while a domestic factory could freely buy the tools to reproduce them. They also make servicing, spare parts, software updates and technical assistance relevant. A tool that is physically shipped legally can still raise a licensing issue when a U.S. person provides restricted support or when software is updated for a controlled process.
How the BIS control stack works
No single test decides every transaction. BIS combines several mechanisms, and a shipment can fall under more than one.
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Performance thresholds
Threshold rules classify chips by technical capability rather than by brand. BIS can set limits around computing performance and related characteristics, then revise them as designs change. Near-threshold products may require a notification or license even when they are not treated exactly like the most capable parts. Because the thresholds and technical definitions have changed repeatedly since October 2022, an old product classification should not be reused without checking the current rule.
Licenses and notifications
A license requirement means the government reviews a proposed transaction; it is not an automatic denial. Review can consider the destination, the purchaser, the facility where the item will be used, ownership, the end use and the compliance controls surrounding the shipment. A license approval is also not the same as unrestricted commercial availability: conditions, reporting duties or limits on resale can remain.
Entity List designations
BIS can place a company, research body or other organization on the Entity List when it determines that the organization presents a heightened proliferation or national-security concern. Listed entities face a license requirement for specified items, often with a policy that makes approval difficult. The December 2024 action added 140 PRC entities, so checking only the immediate buyer is insufficient; distributors, subsidiaries and research partners must also be screened.
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End-use and end-user rules
Even when an item is not blocked solely by its specifications, a prohibited end use—such as certain military, intelligence or advanced-chip activities—or a restricted end user can trigger controls. Companies must document who will operate the equipment, where it will be installed, what process it will run and whether the customer can transfer it onward.
Foreign-direct-product and U.S.-person controls
Foreign-direct-product rules can reach items made outside the United States when specified U.S. technology, software or equipment is used in their production. Separate U.S.-person provisions restrict citizens, permanent residents and companies from supporting certain advanced-chip manufacturing activities, including technical assistance. These provisions mean that a non-U.S. factory cannot assume it is outside U.S. jurisdiction simply because the shipment does not leave American soil.
Key policy milestones and why the date matters
| Date | Policy action | Practical significance |
|---|---|---|
| October 2022 | Initial U.S. advanced-computing and semiconductor-manufacturing controls | Established the core restrictions on advanced chips, manufacturing capability and U.S.-person support. |
| October 2023 | Updated controls | Adjusted technical coverage and addressed ways products could be redesigned to sit just outside the earlier rules. |
| April 4, 2024 | BIS clarification | Explained that the rules restrict China’s ability to buy advanced computing chips and manufacture advanced chips important to military advantage. |
| September 6, 2024 | ASML statement on TWINSCAN NXT:1970i and NXT:1980i | Confirmed that exports of those DUV immersion systems require licenses from the Dutch government. |
| December 2, 2024 | BIS package covering 24 equipment types, three software-tool categories, HBM and 140 PRC Entity List additions | Extended the focus from finished accelerators to the factory bottleneck and supply-chain actors. |
| May 13, 2025 | BIS rescinded the Biden-era AI Diffusion Rule and said officials would not enforce its new requirements while replacement policy was developed | Created a volatile policy interval; the latest Federal Register text controls what is legally effective. |
| January 13, 2026 | Case-by-case review for Nvidia H200, AMD MI325X and similar China-bound chips under stated conditions | Replaced an assumed blanket outcome with conditional review for qualifying applications. |
| May 31, 2026 | BIS guidance on Country Group D:5 and Macau parentage | Clarified that licensing can apply when the customer or ultimate parent is headquartered in those locations, even if the operating entity is elsewhere. |
Why lithography licenses matter for AI
AI performance depends on more than an accelerator’s architecture. Manufacturing determines transistor density, power efficiency, memory interfaces, yield and the volume a supplier can deliver. Lithography projects patterns onto a wafer; etch and deposition shape the layers; implantation and annealing set electrical properties; metrology and inspection find defects. Restricting any critical stage can reduce practical output even when a company has a capable design.
DUV and EUV are not interchangeable labels
Extreme ultraviolet (EUV) and deep ultraviolet (DUV) are different technology categories. The September 6, 2024 ASML statement specifically identifies DUV immersion systems and does not establish a blanket statement that every DUV tool or every EUV tool is prohibited in every destination. The exact model, destination, facility and ownership determine whether a license is needed.
ASML equipment and Dutch licensing
ASML’s September 6, 2024 statement records that exports of its TWINSCAN NXT:1970i and NXT:1980i DUV immersion systems require licenses from the Dutch government rather than the U.S. government. A Dutch license is still a government-reviewed transaction: officials can assess the destination, the receiving facility, ownership, intended use and the current security policy.
ASML said on December 2, 2024 that the updated U.S. rule imposed additional restrictions on suppliers of chip-manufacturing technology and warned that a similar Dutch security assessment could affect DUV immersion exports. For 2025, the company expected total net sales of €30 billion to €35 billion and its China business—net system sales plus net service and field-option sales—to be around 20% of total net sales for that year. That forecast describes ASML’s expected revenue mix, not a measure of how much Chinese capability was lost.
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Can China still obtain advanced AI chips?
Access is conditional, not universally zero. As of the latest policy actions covered here, BIS announced on January 13, 2026 that applications to export Nvidia H200, AMD MI325X and similar chips to China would receive case-by-case review when applicants demonstrate three conditions:
- U.S. customer capacity is not reduced by the proposed sale.
- The Chinese purchaser has effective export-compliance procedures.
- Independent U.S. testing verifies the chip’s performance and security.
Under Secretary Jeffrey Kessler said that allowing H200 sales under controlled conditions would strengthen the American technology ecosystem while protecting national security. The policy therefore creates a route for some transactions, but it does not promise approval, remove end-use restrictions or make the products generally available in China.
How the D:5 and Macau guidance changes screening
BIS guidance dated May 31, 2026 says a license remains required for covered advanced-computing items supplied to an entity headquartered in Country Group D:5 or Macau, or to an entity whose ultimate parent is headquartered there. The rule can apply even when the operating company, data center or purchasing subsidiary is located in another country.
That ownership test changes ordinary customer due diligence. A seller must look beyond the invoice name and identify the ultimate parent, control relationships and the location of headquarters. The same guidance says bona fide data-center operators do not have to stop ongoing use, storage, disposal or servicing solely because of the guidance, until further notice. That protection concerns continued operation of existing equipment; it should not be read as permission for a new shipment or a transfer to a restricted party.
What the controls do in practice
| Controlled item | Main mechanism | Likely operational effect |
|---|---|---|
| Advanced AI accelerator | Performance threshold, license or notification, end-use and end-user review | Sale may be denied, delayed, approved with conditions or redesigned below a threshold. |
| High-bandwidth memory | Specific HBM controls introduced in the December 2, 2024 BIS package | Limits the memory supply needed to build high-throughput AI systems. |
| DUV immersion lithography | Dutch licensing for specified ASML systems; allied controls and destination review | Shipment depends on a government license and facility, ownership and end-use checks. |
| Etch, deposition, implantation, annealing, metrology, inspection and cleaning tools | Equipment controls covering 24 types | Factory expansion, process upgrades and yield improvement can be delayed or require substitution. |
| Chip-design and process software | Controls on three software-tool categories, foreign-direct-product and U.S.-person rules | Design flows, updates and technical support may need licenses or may be unavailable. |
| Transaction involving a listed organization | Entity List licensing requirement | Even an otherwise eligible product can require a difficult license review. |
A compliance workflow for suppliers and data-center operators
Organizations evaluating a chip or lithography transaction should treat classification and ownership as a documented process rather than a one-time check.
- Classify the item. Record the exact chip, HBM component, lithography model, software version or service being supplied. Do not describe a product only as an “AI chip” or “fab tool.”
- Check the current technical rule. Compare the item’s specifications with the current BIS thresholds and control text. Recheck after a rule update, product respin or firmware change.
- Map the transaction. Identify the exporter, consignee, installation site, end user, end use, distributor and every party receiving technical support.
- Trace ownership to the ultimate parent. Apply the May 31, 2026 D:5 and Macau guidance even when the operating entity is incorporated elsewhere.
- Screen restricted parties. Check the Entity List and other applicable lists before contracting, shipping, servicing or transferring the item.
- Assess production support. Review whether U.S. persons, U.S.-origin software or foreign-made products using controlled U.S. technology will provide design, installation, maintenance or process assistance.
- Apply for the correct license. A license application should document customer compliance procedures, the facility, security controls, capacity impact and independent testing where the January 13, 2026 conditional review applies.
- Control post-sale activity. Track reexports, upgrades, spare parts, disposal and service access. An approved first shipment does not automatically authorize every later transaction.
Common misconceptions and how to avoid them
“A license means the shipment will be denied.”
No. Licensing means review. The result can be approval, approval with conditions, delay or denial, depending on the policy and facts of the transaction.
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“A non-U.S. factory is outside U.S. controls.”
Not necessarily. Foreign-direct-product rules and U.S.-person restrictions can reach foreign production and technical support that depend on controlled U.S. technology, software or personnel.
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That overstates the evidence. The cited Dutch requirement concerns the TWINSCAN NXT:1970i and NXT:1980i DUV immersion systems. A precise answer names the model, destination and licensing authority and distinguishes DUV from EUV.
“A case-by-case policy is the same as free trade.”
It is not. Applicants must satisfy the stated security, testing and capacity conditions, and each application remains subject to government judgment and other end-use or end-user rules.
“There is one number showing how much capability the controls removed.”
No authoritative source cited here publishes a single global figure for chips denied, aggregate compute withheld or total performance loss. Claims of a precise worldwide percentage should identify the measurement, date, products and assumptions or be treated cautiously.
What to expect next
Export controls are revised as manufacturers change architectures, packaging, memory and process nodes. A rule can be proposed, rescinded, temporarily unenforced or replaced before a compliance program is updated. The May 13, 2025 treatment of the AI Diffusion Rule illustrates why businesses should read the latest Federal Register text and BIS guidance instead of relying on a headline or an older product memo.
The durable pattern is a layered contest: regulators target compute, memory, production equipment, software, people and ownership; suppliers respond with redesigns, alternative tools, licensing applications and tighter customer controls. For any real transaction, the decisive facts are the exact item, current policy version, destination, ultimate parent, end use and support arrangement.
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