US Chip Export Controls: Impact on Advanced Manufacturing

Against the backdrop of the increasingly fierce competition in the global semiconductor industry,the US Department of Commerce has recently updated the export control provisions,which is another major adjustment after the Chip Act.This update targets the core technologies and equipment for chip manufacturing,including but not limited to EUV masks,etching machines,etc.and at the same time re - clarifies the AI chip license and its exceptions.This move aims to restrict the development of the semiconductor industry in mainland China,especially to block its leap to advanced process technologies.

I.Special Mention of Macau Region and D: 5 Group of Regions

In this export control update,the Macau region is frequently mentioned,aligning with the rules from October 2023,which adopt a "presumption of denial" policy for Macau and D:5 group regions (including mainland China,Iran,Russia,etc.).This means that unless there are exceptional reasons,applications to export controlled AI chips to these regions will be denied by default.The D:5 group is a classification under U.S.export controls,indicating that exports,re-exports,or transfers to these countries and regions are subject to strict restrictions.

II.Exemption from the "Authorized Advanced Computing Power" License

The update introduced a license exemption called "Authorized Advanced Computing," providing certain conveniences for exports under specific circumstances.Specifically,exports of certain AI-related products to countries and regions not in the D:4 or D:5 categories do not require additional licenses if certain conditions are met.

III.Impact on Lithography Machines,RTX4090 and AIPC

(1) Lithography Machines: This update strengthens controls on EUV masks and related equipment,adding "national security" and "regional stability" as new reasons for control,and imposes stricter licensing requirements for exports,re-exports,and other activities to the Macao region and D:5 countries and regions.

(2) RTX4090: For consumer-grade AI chips like the RTX4090,the updated clauses clarify the calculation method and thresholds for performance density,providing clear guidance for the export of certain high-performance chips.

(3) AIPC: For AI processing chips (AIPC),the updated terms provide a clearer scope of application and exceptions,giving enterprises a more definite basis when exporting such products.

IV.Control Objectives and Countermeasures

The main purpose of this update of US export controls is to restrict China from acquiring advanced technologies and equipment in the semiconductor industry,especially those key technologies that can be used in military and advanced computing.In this way,the US hopes to maintain its technological leadership in the global semiconductor industry.At the same time,for national security considerations,it aims to prevent advanced technologies from falling into the hands of potential opponents.

Faced with this situation,Chinese enterprises and research institutions need to adopt a number of countermeasures:

(1) Strengthen independent research and development: Improve the ability of independent research and development and reduce dependence on external advanced technologies and equipment.

(2) Diversify import sources: Explore technological cooperation and equipment procurement from other countries and regions to reduce dependence on a single source.

(3) Comply with laws and regulations: Strictly abide by US export control regulations and introduce technologies and equipment through legal channels.

(4) International cooperation: Strengthen communication with international partners,jointly respond to the US technology blockade,and seek alternative technological paths.

The update of US export controls reflects its strategic considerations in the global semiconductor industry competition.Although the degree of control has been adjusted,its fundamental purpose remains unchanged.Chinese enterprises need to pay close attention to subsequent developments,flexibly adjust their strategies,and strengthen independent technology research and development to cope with the changing international trade environment.