New Research Provides Insight Into Export Control State of Over 100 Chips

New analysis from Georgetown University’s Center for Security and Emerging Technology includes a table of more than 100 types of semiconductors and whether they’re subject to U.S. export licensing requirements. CSET also said a new red flag recently published by the Bureau of Industry and Security could cause foundries to ask more questions of customers seeking to produce advanced chips.

The interactive table, included in research published this week, allows users to sort through various semiconductors and their designers, along with whether each chip is captured by an Export Control Classification Number and information on their total processing performance, performance density and more.

The analysis, authored by CSET research analyst Hanna Dohmen and data research analyst Jacob Feldgoise, notes that the Bureau of Industry and Security's recently updated Oct. 17 chip controls “revamped the criteria” companies used to determine which semiconductors are subject to licensing requirements (see 2310170055). The agency “notably” removed the interconnect speed parameter included in its original Oct. 7, 2022, controls (see 2210070049), CSET said, and now identifies controlled chips using their total performance, performance density and "whether the chip is 'designed or marketed' for use in a datacenter."

“Under this updated system, a lot more chips are controlled,” CSET said, “including high-performing gaming chips and lower-performing datacenter chips -- not just those chips needed to train frontier [artificial intelligence] models.”

Although the analysts said their interactive table isn’t a compliance tool -- and urged companies to seek out legal advice when determining whether their chip is subject to export controls -- it provides a detailed snapshot of the range of chips potentially captured by the U.S. restrictions and how their performance capabilities differ. Of the 130 chips listed, the table notes that it’s “unknown” whether 14 of them require a license.

The analysis also pointed to a new red flag published by BIS as part of the Oct. 17 controls, which suggested a foundry has a “duty to investigate” a scenario in which it determines a customer, based on the design files, is looking to produce integrated circuits, a computer, electronic assemblies or components that will “incorporate more than 50 billion transistors and that will have high-bandwidth memory.” CSET said foundries that identify a red flag may ask customers more questions, request to meet, or “analyze the products in greater detail.”

“While foundries may resolve their suspicions through this process, firms often go many steps beyond the text of the regulations to ensure they ‘know’ they are not committing a violation,” CSET said. “With the addition of this new red flag, BIS has likely made it significantly more difficult for Chinese design firms to circumvent U.S. export controls.”

The analysts added that they expect the updated controls will force Chinese companies to “rely on their stockpiles of previously imported chips and less-advanced chips,” and Chinese firms could feel more pressure to “indigenize and find domestic alternatives” to export-controlled technologies.

“But ultimately, how these effects will translate to slowing China’s ability to use large-scale AI models to develop [weapons of mass destruction] and advanced conventional weapons or pursue broader military modernization goals is an open question.”