The Export Control Architecture
The U.S. export control response to Chinese semiconductor ambitions began in earnest with the addition of Huawei to the Commerce Department's Entity List in May 2019. The designation required U.S. suppliers to obtain licenses — effectively denied — before selling components, software, or technology to Huawei. A subsequent rule extending the restriction to foreign-made products incorporating U.S. technology cut off Huawei's access to TSMC-manufactured chips designed with U.S. electronic design automation software.
The October 2022 semiconductor export controls represented a significant expansion of the architecture. The rules imposed new restrictions on the export of advanced logic chips (at or below 16nm finFET), advanced memory chips (128-layer NAND and above, 18nm DRAM and above), and the semiconductor manufacturing equipment needed to produce them. The rules also imposed foreign direct product rules requiring non-U.S. companies using U.S. technology to obtain licenses before supplying restricted items to Chinese customers.
Subsequent updates in October 2023 and 2024 tightened the controls further, closing loopholes that had allowed the export of chips slightly below the original performance thresholds, extending restrictions to additional countries of concern, and adding new Chinese semiconductor companies to the Entity List. The controls have been coordinated — imperfectly — with allied governments, with the Netherlands restricting ASML's export of deep ultraviolet lithography equipment and Japan imposing controls on 23 categories of semiconductor manufacturing equipment.