US Imposes Export Controls on AI Memory Chips to China

Washington, D.C. - The U.S. Commerce Department's Bureau of Industry and Security (BIS) announced new controls on high-bandwidth memory (HBM) semiconductors on Monday, expanding restrictions on exports to China and other countries of concern.

According to the interim final rule published in the Federal Register, the controls require licenses for HBM chips with memory bandwidth density greater than 2 gigabytes per second per square millimeter when exported to China or Macau.

BIS created a new Export Control Classification Number (ECCN) 3A090.c to control these specialized memory chip critical components in advanced artificial intelligence data centers and supercomputing applications.

The agency established a new License Exception HBM that permits certain exports to packaging sites owned by U.S. and allied companies, provided the HBM has a memory bandwidth density below 3.3 GB/s/mm².

The exception requires exporters to be headquartered in the United States or allied nations and mandates direct shipment to packaging sites. 

Companies must confirm shipment quantities match returns and report discrepancies exceeding one percent within 60 days.

"These rules aim to effectively address the national security and foreign policy considerations while providing a more efficient authorization process for certain exports that are in U.S. interests," BIS stated in the rule.

The regulations include new notification requirements. 

Companies must report shipping details 45 days before export and installation confirmations within 30 days. 

Annual end-use verification reports are also required.

The controls take effect December 31, 2024. BIS accepts public comments on the interim final rule until January 31, 2025.