China Semiconductor Export Regulations, Episode III – What A Difference A Year Makes

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Key Takeaways

• Advanced Computing and Supercomputing ECCNs are expanded.
• Controls applied to exports to countries other thanChina; countries from where items may be reexported to China.
• Chipmaking equipment controls are expanded and the de minimis rule reduced.
• New entities are added to the U.S. Entity List with the Footnote 4 (FN4) FDPR designation.
• More U.S.-person activity is controlled.

Background

On Tuesday, October 17, 2023, the U.S. Bureau of Industry and Security (BIS) released a package of three rules (the 2023 Rules) targeting the Chinese semiconductor industry. The rules update the substantial semiconductor regulations that BIS released a year ago (the 2022 Regulations), reshaping the semiconductor industry and its flows of information and trade between the United States and China.