Export controls tighten

- US export rules are increasingly restricting high-end AI hardware transfers to China, adding supply frictions. - Commerce Secretary Howard Lutnick said Nvidia has not yet sold any H200 AI chips to China. - Lawmakers are pursuing tighter loopholes like an "Affiliates Rule," raising compliance burdens and supplier uncertainty (reuters.com).

Nvidia still has not sold any H200 artificial intelligence chips to China, even after Washington opened the door to those exports in January. (reuters.com) U.S. Commerce Secretary Howard Lutnick told senators on April 22 that no H200 sales have closed because Chinese companies have struggled to get approval from their own government. The Trump administration had shifted in January to review H200 export licenses case by case. (reuters.com) (bis.gov) The House Foreign Affairs Committee, meanwhile, advanced a package of export-control bills on April 22 aimed at tightening how the United States restricts chips, artificial intelligence systems and related tools bound for China. Bloomberg reported the markup showed growing bipartisan support for tougher curbs. (bloomberg.com) (democrats-foreignaffairs.house.gov) The immediate issue is not just whether a chip is legal to export. It is whether companies can predict the rules long enough to line up customers, licenses, financing and supply from foundries and server makers. (bis.gov) (reuters.com) That uncertainty has been building since October 2023, when Washington tightened controls on advanced artificial intelligence chips and Nvidia responded with lower-spec products for China, including the H20. In April 2025, Nvidia said new U.S. licensing limits on H20 exports would force a roughly $5.5 billion charge. (cnbc.com 1) (cnbc.com 2) Congress is now also pressing on a separate weak spot: affiliates of blacklisted companies. The Bureau of Industry and Security issued an “Affiliates Rule” in 2025 to extend some controls to certain foreign affiliates of listed entities, then suspended it for one year on November 10, 2025 as part of a U.S.-China trade deal. (millerchevalier.com) (natlawreview.com) That suspension means companies now have a countdown running toward November 2026 unless Commerce changes course again. Trade lawyers have said the rule would require deeper ownership checks across customers, subsidiaries and sister companies before shipments move. (millerchevalier.com) (conventuslaw.com) Lawmakers are also trying to make the chip thresholds themselves move automatically as China’s domestic technology improves. Representative John Moolenaar introduced the SCALE Act on April 21 to create a “clear standard” for restricting advanced semiconductor sales to China. (chinaselectcommittee.house.gov) Nvidia has argued for clearer and more durable rules as it tries to keep a foothold in China without crossing U.S. red lines, while Washington keeps adding new tests for what can ship and to whom. For now, the headline result is simple: a chip Washington says may be sold still is not moving. (reuters.com) (bis.gov)

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