US Chip Export Controls Timeline: Every Major BIS Rule on China Since 2022
This page tracks the main US rules that limit China’s access to advanced chips, AI accelerators and chipmaking equipment. It starts with the October 2022 package and runs to the guidance Washington issued in 2026. Entries are in date order, and each one says what changed and who felt it.
Last updated: 15 September 2026.
How the controls work
The Bureau of Industry and Security (BIS) sits inside the US Commerce Department and writes the Export Administration Regulations (EAR). Chip controls lean on a handful of levers. Technical thresholds decide which chips and tools need a licence. End-user lists such as the Entity List name companies that need a licence for almost anything. Foreign direct product rules stretch US jurisdiction to items made abroad with US tools or software. A separate “US persons” rule limits what Americans can do to support advanced fabs in China.
Most entries below change one of those levers.
2022
7 October 2022: The first broad package
BIS published its largest semiconductor rule to that point. It created licence requirements for high-end AI and supercomputing chips shipped to China, using a mix of processing performance and chip-to-chip interconnect speed. It also restricted equipment for making logic chips at roughly 16/14nm and below, DRAM at 18nm half-pitch and below, and NAND flash with 128 or more layers. US persons were barred from supporting advanced fabs in China without a licence.
Nvidia answered with the A800 and H800, cut-down versions of its data centre GPUs designed to slip under the interconnect threshold.
2023
17 October 2023: Closing the A800 and H800 gap
The update dropped the interconnect test and switched to total processing performance (TPP) and performance density. That caught the A800 and H800. Licence requirements were extended to a wider group of countries to limit diversion through third markets, and more Chinese chip designers went onto the Entity List.
Nvidia’s next China product, the H20, was built to sit below the new thresholds.
2024
2 December 2024: High-bandwidth memory and more tools
This package added controls on high-bandwidth memory (HBM), the stacked DRAM that sits beside AI accelerators. It covered more types of chipmaking equipment and related software, added about 140 entities, and widened the foreign direct product rules so more foreign-made tools fell under US control.
China responded within days by banning exports of gallium, germanium and antimony to the United States.
2025
13 January 2025: The AI Diffusion Rule
In its final week the Biden administration issued a global framework for AI chips and model weights. Countries fell into three tiers. The US and 18 close partners faced no new licensing. Most of the world would buy under country caps and a data centre validated end-user programme. China and other arms-embargoed destinations stayed shut out. The rule also controlled the weights of closed models trained above 10^26 operations.
15 January 2025: Foundry due diligence
A second rule targeted contract manufacturers. Front-end fabs and packaging houses had to take extra steps before making advanced chips for customers who might be fronting for restricted Chinese designers, with a path for “approved” designers and packagers. BIS added 16 more entities the same day.
March 2025: Dozens of new listings
The new administration added roughly 80 organisations to the Entity List, many tied to high-performance computing, AI and quantum work in China.
April 2025: The H20 needs a licence
Nvidia disclosed that the US government now required a licence to ship the H20 to China, and took a multibillion-dollar charge on inventory. AMD’s MI308 was caught by the same move.
13 May 2025: AI Diffusion Rule rescinded
BIS said it would not enforce the AI Diffusion Rule and would replace it. Alongside the rescission it issued guidance warning that using Huawei Ascend chips anywhere in the world could breach US rules, since those chips were likely made with US technology.
Summer 2025: H20 sales resume
Licences for the H20 began to flow again in July and August. Reports described an unusual arrangement in which Nvidia and AMD would pass a share of China revenue to the US government. Chinese regulators discouraged local companies from buying the chip.
29 August 2025: Validated end-user status revoked
BIS removed Samsung’s and SK hynix’s China fabs, along with Intel’s former Dalian plant, from the validated end-user (VEU) programme, effective 31 December 2025. TSMC’s Nanjing fab lost its status too. From January 2026 these plants needed regular licences for US tools.
29 September 2025: The Affiliates Rule
The Affiliates Rule, often called the BIS 50% rule, applied Entity List restrictions automatically to any company at least 50% owned by listed parties. Before it, a wholly owned subsidiary of a listed company could often buy freely unless it was named too.
10 November 2025: Affiliates Rule suspended
After the Trump–Xi meeting in Busan, BIS suspended the Affiliates Rule for one year. The suspension ends on 9 November 2026 unless BIS extends it, and the rule’s licence requirements are written to return on 10 November 2026.
8 December 2025: H200 cleared in principle
President Trump said Nvidia could sell the H200 to approved Chinese customers. The H200 is a big step above the H20, though still behind Nvidia’s Blackwell generation.
2026
15 January 2026: The H200 rule
BIS changed licence review for H200-class chips headed to China and Macau from a presumption of denial to case-by-case review. The AMD MI325X qualifies on the same terms. Applicants have to show China sales won’t eat into supply for US customers, that the buyer screens its own customers, and that the product passed independent testing in the United States. On the same day a presidential proclamation put a 25% tariff on such chips when they pass through the US on their way abroad.
The core China controls did not change. Chipmaking equipment limits, Entity List denials, the US persons rule and the foreign direct product rules all stayed in force.
Early 2026: Enforcement steps up
With new rulemaking slowed during trade talks, BIS leaned on penalties. The largest was a settlement of about $252 million with Applied Materials, the second-highest penalty in the agency’s history.
31 May 2026: Chinese-headquartered firms abroad
BIS issued guidance confirming that licence requirements for advanced AI chips cover any company headquartered in China or with a Chinese parent, wherever the buyer is located. The guidance answered questions left open when the AI Diffusion Rule was scrapped, and it made clear that Blackwell sales to Chinese-owned subsidiaries outside China need a licence.
What to watch next
The Affiliates Rule is due to return on 10 November 2026. China’s own suspended mineral controls expire around the same time, so the two dates are likely to be negotiated together.
BIS has also said it is drafting a replacement for the AI Diffusion Rule. That framework will decide whether chip access abroad is governed by one global system or a string of bilateral deals.
Quick reference
| Date | Measure | Main effect |
|---|---|---|
| 7 Oct 2022 | First advanced computing and SME rule | Licences for top AI chips and advanced fab tools |
| 17 Oct 2023 | Threshold update | A800 and H800 caught; wider country scope |
| 2 Dec 2024 | HBM and SME expansion | HBM controlled; about 140 entities added |
| 13 Jan 2025 | AI Diffusion Rule | Three-tier global licensing (later rescinded) |
| 15 Jan 2025 | Foundry due diligence | Checks on contract chipmakers |
| Apr 2025 | H20 licence requirement | H20 and MI308 need licences |
| 13 May 2025 | Diffusion Rule rescinded | Huawei Ascend guidance issued |
| 29 Aug 2025 | VEU revocations | Samsung, SK hynix and TSMC China fabs need licences |
| 29 Sep 2025 | Affiliates Rule | 50%-owned subsidiaries covered |
| 10 Nov 2025 | Affiliates Rule suspended | Pause until 9 Nov 2026 |
| 15 Jan 2026 | H200 rule | Case-by-case review with conditions |
| 31 May 2026 | Headquarters guidance | Chinese-parented firms abroad need licences |