The US Department of Commerce has published new guidelines according to which export licences for certain high-performance chips to China will be reviewed. The Bureau of Industry and Security (BIS) is responsible for this.
In future, the BIS intends to evaluate applications for export licences for the Nvidia H200, the AMD MI325X and comparable chips on a case-by-case basis and subject them to strict scrutiny. A licence will be granted if certain security requirements are met.
The background to this is an announcement made by President Trump on 8 December 2025, in which he stated that the United States intends to allow the shipment of the H200 and similar products to approved customers in China. The aim is to strengthen national security while ensuring the technological competitiveness of the US.
In their licence applications, companies must demonstrate that exporting these products to China will not reduce the globally available semiconductor production capacity for US customers. In addition, the buyer in China must have export compliance procedures in place, including systematic customer screening. Furthermore, the product in question must have been tested in the United States by independent third parties to verify its performance and safety.
Even if the US reopens the export route, China appears to be blocking deliveries, at least in part. According to recent reports, there are also problems with customs clearance.
Links:
Revision to License Review Policy for Advanced Computing Commodities
Department of Commerce Revises License Review Policy for Semiconductors Exported to China
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