[Insights] Unleashing the Practical Impacts of U.S. Semiconductor Export Policies on China

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On October 17, 2023, the U.S. government unveiled an updated set of regulations for semiconductor exports, introducing stricter standards for advanced AI chips. Additionally, these regulations expand control over the export of exposure equipment and include Chinese GPU design startups on an Entity List.

TrendForce’s Insights: 

1. New regulations cover chips, manufacturing equipment, and related companies, signaling an effort to restrain China’s AI development.

In this latest set of regulations, the U.S. has relaxed the I/O bandwidth restrictions for AI chips and introduced three additional conditions beyond a total processing performance (TPP) of ≥ 4800 TOPS:

(1) Total processing performance ≥ 1600 TOPS and performance density (PD) ≥ 5.92

(2) Total processing performance ≥ 2400 TOPS but < 4800 TOPS and performance density ≥ 1.6 but < 5.92

(3) Total processing performance ≥ 1600 TOPS and performance density ≥ 3.2 but < 5.92

As a result of these new conditions, NVIDIA’s A800, H800 GPU, and the recent launched L40S GPU for the Chinese market are now included in the list of controlled exports, similar to the A100 and H100 GPUs that were added in September 2022.

Concerning manufacturing equipment, the control threshold for exposure equipment has shifted from single-machine (specified substrate) coverage precision of ≤ 1.5nm to > 1.5nm but ≤ 2.4nm. This change directly led to the inclusion of ASML’s 1980Di DUV lithography machines.

On the corporate front, Chinese domestic GPU design startups such as Birentech, Moore Threads, and high-speed DSP design company Superfusion Semiconductor, along with their related entities, have been placed on the Entity List by the U.S. Department of Commerce.

In summary, these new regulations encompass chips, manufacturing equipment, and related companies. The U.S. is not only controlling the current mainstream AI product lines and applications of DUV lithography machines for 28-7nm processes but is also making a clear effort to interfere Chinese domestic manufacturers’ development of AI computation chips, indicating a strong determination to restrict China’s growth in the AI sector.

2. Priority for Chinese Enterprises: Securing AI Computing Resources through Cloud Service Providers

In light of the impact of the new U.S. semiconductor control regulations, Chinese domestic companies will be limited to AI chip performance not exceeding that of NVIDIA L40 GPU. As leading companies like NVIDIA, AMD, Intel, and others continuously boost the performance of their AI chips, the gap between the AI computing resources established by Chinese companies and their international counterparts will continue to widen.

Looking at it from an angle of independent research and development, with the inclusion of 1980Di and more advanced DUV lithography machines in the control list and the U.S. Department of Commerce placing Chinese IC design companies on the Entity List, short-term mass production of high-performance server AI chips in China seems unlikely.

Faced with challenges in both outsourcing and in-house production, the primary path for Chinese domestic companies to develop AI technology and applications is to obtain high-performance AI computing resources from international cloud service providers (CSP). It is worth noting that the U.S. government is also exploring limitations on Chinese firms attempting to evade semiconductor control policies through CSP. For Chinese companies, establishing robust customer relationships and building extensive AI computing resources are pressing priorities before related policies are enacted.
(Image: Pixabay)