Compute export controls are government controls over who can buy chips for training and running AI, the memory for them and the equipment to manufacture them. The main example is the US restrictions, in force since 2022, on selling advanced AI chips from NVIDIA and other companies to China; China responds with bans on exporting raw materials for semiconductors and with pressure on American companies.
Compute has become a strategic commodity, as uranium once was: governments decide who will have more of it, and therefore who will have the most powerful models. By 2026 the controls had turned into a pendulum. The US alternately bans sales and allows them in exchange for a levy, Beijing in turn restricts its companies from buying what has been allowed, and smuggling, according to an estimate by Epoch AI, has given China about a third of its computing capacity.1
History
- 18.02.2015The US adds the Chinese military university NUDT and three national supercomputing centers to the Entity List: according to the authorities, the Tianhe supercomputers “are believed to be used in nuclear explosive activities”.2 ¶ cxd7eewsh
- 16.05.2019Huawei and 68 of its foreign affiliates are added to the Entity List.3 ¶ c8xyxg6sp
- 17.08.2020The US Commerce Department expands the “foreign direct product rule”: a license is now also needed for chips made abroad for Huawei using American technology, which cuts Huawei off from TSMC’s fabs.4 ¶ csij6yziz
- 26.08.2022The US government informs NVIDIA that exports of A100 and H100 chips to China, Hong Kong and Russia now require a license.5 ¶ cg9k6vuer
- 07.10.2022The Commerce Department’s Bureau of Industry and Security (BIS) restricts sales to China of advanced AI chips and semiconductor manufacturing equipment.6 ¶ cr357sfmp
- 03.07.2023China introduces export controls on gallium and germanium, raw materials for semiconductors; the rule takes effect on 01.08.2023.7 ¶ cqx2dt8su
- 17.10.2023BIS closes a loophole: the cut-down A800 and H800, which NVIDIA made for China to fit the 2022 rules, fall under a new “performance density” threshold; for NVIDIA the ban takes effect immediately, on 23.10.2023.89 ¶ cugs2mzkm
- 02.12.2024BIS introduces controls on HBM memory and 24 more types of equipment, and adds 140 entities to the Entity List.10 ¶ chpuiqpk3
- 03.12.2024China bans in principle the export of gallium, germanium, antimony and superhard materials to the US.11 ¶ ce76xgfsw
- 13.01.2025The US adopts the “AI diffusion rule”: licenses for AI chips for almost the whole world, with countries divided into three tiers, and controls on the weights of closed models trained with 10²⁶ operations or more. On 13.05.2025 the new administration announces that it will rescind the rule.1213 ¶ cbyk82dfj
- 04.04.2025China introduces export controls on 7 medium and heavy rare earth metals, including magnets.14 ¶ cam57uiuh
- 14.04.2025The US informs NVIDIA that a license to export the H20 chip, designed for China under the previous rules, “will be in effect for the indefinite future”; the company expects up to $5.5 billion in charges.15 ¶ cmg2pqkqs
- 08.2025The US issues licenses for the H20; officials expect the government to receive 15% of the revenue from these sales, but there is no regulation providing for it.16 ¶ cnqktqzhj
- 07.11.2025After the meeting of the US and Chinese leaders in Busan, China suspends some of its restrictions until 10.11.2026, and on 09.11.2025 its ban on exporting gallium and germanium to the US until 27.11.2026.17 ¶ c97qqfvv9
- 13.01.2026BIS begins reviewing applications to export the H200 and AMD MI325X to China “on a case-by-case basis” instead of the previous presumption of denial.18 ¶ cx9d9mfb3
- 10.07.2026The US allows the UAE government and approved companies to receive advanced chips and servers without licenses.19 ¶ c7dshcje8
How it works
The controls work through three levers. Chip thresholds: chips faster than a set limit are banned. Equipment and memory: without machines for making chips and without HBM memory, a country cannot build its own production. The Entity List and the direct product rule: a license is needed for any item destined for a listed entity, and even for chips made abroad using American technology.2410
The line is drawn by performance. The 2022 rule cut off chips with a computing power of at least 4,800 “bits × TOPS” and chip-to-chip data transfer of at least 600 GB/s; NVIDIA responded with the A800 and H800, with reduced chip-to-chip interconnect. In 2023 BIS introduced the TPP (total processing performance) metric and “performance density”, power per square millimeter of die area. As the rule itself explains, this “prevents the workaround of simply purchasing a larger number of smaller datacenter AI chips which, if combined, would be equally powerful as restricted chips”.20 ¶ cgygz5tp9
China responds in kind, with control over raw materials without which semiconductors cannot be made (gallium, germanium, rare earth metals), and with investigations of American companies.714
Data
| study | what was measured | result |
|---|---|---|
| NVIDIA, 10-K report, 25.02.202621 | share of China (including Hong Kong) in the company’s revenue, by customer headquarters location; company data | 19% in fiscal 2025, 9% in fiscal 2026 ¶ cequth78s |
| NVIDIA, 28.05.202522 | losses from the H20 ban in one quarter | a $4.5 billion charge, a further $2.5 billion not shipped; the outlook for the next quarter includes a loss of about $8 billion in revenue ¶ cu5wj5j8q |
| Epoch AI, 05.06.202523 | countries’ shares of the performance of tracked GPU clusters as of May 2025; incomplete sample | US about three quarters, China 15% ¶ cfbvytppv |
| DeepSeek, 12.202424 | training of the DeepSeek-V3 model on chips cut down for China; only the final run is counted | 2,048 H800 chips, 2.788 million GPU hours, about $5.6 million at rental prices ¶ cha79kyhg |
| Epoch AI, 29.04.20261 | cumulative chip smuggling into China through the end of 2025; estimate | from 290,000 to 1.6 million H100 equivalents, median 660,000, roughly a third of all China’s computing capacity ¶ cep5xgvej |
| SEMI, 07.04.202625 | purchases of chipmaking equipment in 2025 | China $49.3 billion of $135.1 billion worldwide, about 36% ¶ cf23qbhse |
The controls are costly for American companies (NVIDIA has lost billions of dollars and almost the entire Chinese market) but do not cut China off from compute. The US still holds most of the world’s capacity, yet Chinese labs train strong models on cut-down chips, about a third of China’s capacity arrived, by one estimate, through smuggling, and China is buying up equipment to make chips itself. Caveats: the country shares are calculated from an incomplete sample of clusters, smuggling estimates differ several-fold, and the cost of training DeepSeek covers only the final run. ¶ cdz8se5vw
Incidents
“Operation Gatekeeper”: an H100 and H200 smuggling network, December 2025 ¶ crp69myfh
On 08.12.2025 the US Department of Justice announced that it had shut down a major network smuggling AI chips into China: from October 2024 to May 2025 its members exported or tried to export NVIDIA H100 and H200 chips worth at least $160 million. More than $50 million in equipment and cash was seized.26
$300 million in servers via Malaysia and Singapore, October 2026 ¶ cwstv8ne2
On 01.10.2026 the owner of a technology company was arrested in California: according to the charges, he shipped servers with American graphics processors worth more than $300 million to China, first to Malaysia and Singapore, where no license is needed, and from there to China.27
Criticism
On NVIDIA’s earnings call on 28.05.2025, Jensen Huang said: “The U.S. has based its policy on the assumption that China cannot make AI chips. That assumption was always questionable, and now it’s clearly wrong.” In his words, “the $50 billion China market is effectively closed to U.S. industry”.28 ⧗ ¶ c9f44mwii
In January 2025, after the release of DeepSeek, Anthropic CEO Dario Amodei wrote: “This shows that the export controls are actually working and adapting: loopholes are being closed”. A significant share of DeepSeek’s chips, he wrote, were permitted ones, imported before the ban, or smuggled. Loopholes must be closed faster; of the H20 he wrote, “although I think they should be banned”.29 ¶ cxf8bn296
On 11.06.2025 CNAS analysts estimated that “AI chip smuggling has likely been occurring at a scale that significantly undermines U.S. attempts to restrict the People’s Republic of China’s (PRC’s) access to advanced AI”; the median estimate is about 140,000 chips in 2024.30 ¶ cm28abpy3
On 11.08.2025 China’s Ministry of Foreign Affairs restated its official position: China stands for “opposing the politicization and weaponization of tech and trade issues”. “Such practices disrupt the stability of global industrial and supply chains and are in no one’s interests.”31 ¶ cnyhvs8rs
Asked about funding in a 2024 interview, DeepSeek founder Liang Wenfeng answered: “Money has never been the problem for us; bans on shipments of advanced chips are the problem.”32 ⧗ ¶ cpja5u8ig
Evolution
Huawei is building a replacement for American chips: on 18.09.2025 the company announced its plan for new Ascend chips, “we will follow a 1-year release cycle and double compute with each release”, and acknowledged that “The Chinese mainland will lag behind in semiconductor manufacturing process nodes for a relatively long time.” That is why it is betting on combining many chips into a single supercomputer.33 ¶ cs8vkb6xw
US policy is moving in two directions at once: sales to China are partly allowed, with inspection in the US and a 25% levy on the H200, while allies such as the UAE get chips without licenses. Beijing, meanwhile, restricts its companies from buying the American chips that have been allowed: H200 sales to China in the latest quarter amounted to less than 1% of NVIDIA’s data center revenue.34 ¶ capzix4cx
The next turning points are 10.11 and 27.11.2026, when China’s suspensions expire.17
See also
References
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Isabel Juniewicz. Diversion and resale: estimating compute smuggling to China — Epoch AI, 29.04.2026. epoch.ai ↩ ↩2
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Addition of Certain Persons to the Entity List — Federal Register 80 FR 8524, BIS, 18.02.2015. govinfo.gov ↩ ↩2
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Addition of Entities to the Entity List — Federal Register 84 FR 22961, BIS, 21.05.2019. govinfo.gov ↩
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Commerce Department Further Restricts Huawei Access to U.S. Technology and Adds Another 38 Affiliates to the Entity List — U.S. Department of Commerce, 17.08.2020. content.govdelivery.com ↩ ↩2
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Commerce Implements New Export Controls on Advanced Computing and Semiconductor Manufacturing Items to the People’s Republic of China — BIS, 07.10.2022. bis.gov ↩
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商务部 海关总署公告2023年第23号 — Ministry of Commerce of the PRC, 03.07.2023. mofcom.gov.cn ↩ ↩2
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Commerce Strengthens Restrictions on Advanced Computing Semiconductors, Semiconductor Manufacturing Equipment, and Supercomputing Items to Countries of Concern — BIS, 17.10.2023. bis.gov ↩
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Commerce Strengthens Export Controls to Restrict China’s Capability to Produce Advanced Semiconductors for Military Applications — BIS, 02.12.2024. bis.gov ↩ ↩2
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商务部公告2024年第46号 — Ministry of Commerce of the PRC, 03.12.2024 (reprint). cn.chinadaily.com.cn ↩
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Biden-Harris Administration Announces Regulatory Framework for the Responsible Diffusion of Advanced Artificial Intelligence Technology — BIS, 13.01.2025. bis.gov ↩
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Department of Commerce Announces Rescission of Biden-Era Artificial Intelligence Diffusion Rule — BIS, 13.05.2025. bis.gov ↩
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商务部 海关总署公告2025年第18号 — Ministry of Commerce of the PRC, 04.04.2025. mofcom.gov.cn ↩ ↩2
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NVIDIA Corporation, Form 10-Q for the quarter ended 26.10.2025 — SEC. sec.gov ↩
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商务部公告2025年第70号 — Ministry of Commerce of the PRC, 07.11.2025. mofcom.gov.cn; 商务部公告2025年第72号 — 09.11.2025. mofcom.gov.cn ↩ ↩2
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Department of Commerce Revises License Review Policy for Semiconductors Exported to China — BIS, 13.01.2026. bis.gov ↩
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Department of Commerce Eases Export Controls for UAE — BIS, 10.07.2026. bis.gov ↩
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Implementation of Additional Export Controls: Certain Advanced Computing Items; Supercomputer and Semiconductor End Use — Federal Register 88 FR 73458, BIS, 25.10.2023. federalregister.gov ↩
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NVIDIA Corporation, Form 10-K for fiscal year 2026 — SEC, 25.02.2026. sec.gov ↩
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NVIDIA Announces Financial Results for First Quarter Fiscal 2026 — NVIDIA, 28.05.2025. sec.gov ↩
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The US hosts the majority of GPU cluster performance, followed by China — Epoch AI, 05.06.2025. epoch.ai ↩
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DeepSeek-AI. DeepSeek-V3 Technical Report — arXiv, 27.12.2024. arxiv.org ↩
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SEMI Reports Global Semiconductor Equipment Billings Reached $135 Billion in 2025 — SEMI, 07.04.2026. semi.org ↩
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U.S. Authorities Shut Down Major China-Linked AI Tech Smuggling Network — U.S. Department of Justice, 08.12.2025. justice.gov ↩
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California Man Arrested for Smuggling More Than $300 Million in Export-Controlled Computer Servers to China — U.S. Department of Justice, 01.10.2026. justice.gov ↩
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NVIDIA, First Quarter Fiscal 2026 earnings call — 28.05.2025 (third-party transcript). allmind.ai ⧗ ↩
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Dario Amodei. On DeepSeek and Export Controls — 01.2025. darioamodei.com ↩
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E. Grunewald, T. Fist. Countering AI Chip Smuggling Has Become a National Security Priority — CNAS, 11.06.2025. cnas.org ↩
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Foreign Ministry Spokesperson Lin Jian’s Regular Press Conference on August 11, 2025 — Ministry of Foreign Affairs of the PRC, 11.08.2025. fmprc.gov.cn ↩
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Deepseek: The Quiet Giant Leading China’s AI Race — ChinaTalk, 27.11.2024 (translation of an interview with 暗涌 Waves, 07.2024). chinatalk.media ⧗ ↩
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Eric Xu: keynote speech at Huawei Connect 2025 — Huawei, 18.09.2025. huawei.com ↩
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NVIDIA Corporation, Form 10-Q for the quarter ended 26.07.2026 — SEC. sec.gov ↩