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ARTICLE · 21 JANUARY 2026

Administration Policies On Advanced AI Chips Codified, With Reverberations Across AI Ecosystem

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Commerce rule eases licensing for advanced AI chips to China and establishes new criteria for license applications; Presidential Proclamation imposes 25% tariff on covered advanced chip imports when intended for any customer outside United States.

United StatesTechnology
Daniel Harder
Daniel Harder
Aiysha Hussain
Aiysha Hussain
Tamer A. Soliman
Tamer A. Soliman
Warren S. Payne
Warren S. Payne
Thea Kendler
Thea Kendler
Stephanie R. Jebeyli
Stephanie R. Jebeyli
An Shen
An Shen
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Commerce rule eases licensing for advanced AI chips to China and establishes new criteria for license applications; Presidential Proclamation imposes 25% tariff on covered advanced chip imports when intended for any customer outside United States

In the last week, the Trump Administration has taken several actions to formalize policies enabling the export of advanced AI semiconductor chips to China and PRC companies. Each measure has repercussions across the AI ecosystem.

On January 13, 2026, the US Department of Commerce's Bureau of Industry and Security ("BIS") released a final rule revising the license review posture for commercially available NVIDIA H200- and AMD MI325X-equivalent chips and chips with lesser performance from "presumption of denial" to "case-by-case review." With this rule, BIS established specific technical, business, end user, and US market certifications exporters must make to benefit from the revised policy, including identification of

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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