U.S. Policy Shift on Chip Exports to China: A Calculated Strategic Game

On [Date], the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) quietly published a new regulation in the Federal Register. The core content of this document involves revising the license review policy for exports of advanced computing semiconductors to China. The previously applicable "presumption of denial" principle for the export of specific chips has been adjusted to "case-by-case review under certain conditions." This means that advanced chips such as NVIDIA’s [Chip Model] and [Another Chip Model], which were previously subject to strict restrictions, have regained the possibility of re-entering the Chinese market after meeting a series of stringent conditions.

This official document marks a significant and complex shift in U.S. policy since the Biden administration initiated export controls on advanced semiconductors to China. It is not a simple "lifting of restrictions," but rather a strategically calculated adjustment under multiple pressures—national security, economic interests, technological competition, and geopolitics. On the chessboard of this game, what is at stake is not merely chips, but the chips representing future dominance in artificial intelligence.

Policy Relaxation: From "Presumptive Denial" to "Conditional Approval"

The introduction of the new regulations did not come without warning. At the end of last year, President Trump, after being re-elected, signaled that he would allow the export of advanced chips to "approved customers" in China, subject to a % government surcharge. This was widely seen as a response to months of lobbying by NVIDIA CEO Jensen Huang. Now, the shoe has dropped, but the manner in which it has landed is far more complex than a simple "export allowed."

The subtle setting of technical barriers是新规的第一个关键点。要获得出口许可，芯片的总处理性能（TPP）得分必须低于21,000点，且总DRAM带宽低于每秒6,500 GB。英伟达H200的TPP得分约为15,832，带宽约每秒4,800 GB；AMD MI325X的TPP得分约20,800，带宽约每秒6,000 GB。两者都“恰好”卡在门槛之下。这种设定绝非偶然，它精准地将当时最顶级的、可能带来颠覆性算力优势的芯片（如英伟达的Blackwell架构芯片和未来的Rubin芯片）排除在外，同时为次一级但仍属先进的产品打开了狭窄的门缝。

"America First" Supply Security is the second core condition. Exporters must prove that domestic demand in the United States has been fully satisfied. This means that orders from U.S. customers cannot be delayed due to exports to China, and U.S. manufacturing capacity cannot be diverted to fulfill Chinese orders. More critically, The total shipments to China (including Macau) must not exceed % of the total shipments of the same product to domestic customers in the United States during the same period.. This clause has been interpreted by industry observers as positioning the Chinese market as a "dumping ground for surplus capacity" of the U.S. market. The hardware news site Tom's Hardware's comment hits the nail on the head: this essentially monetizes some commercial interests under the premise of ensuring U.S. industrial dominance.

Layer-by-layer security review constitutes the third, and perhaps the most cumbersome, checkpoint. All chips intended for export must be verified by an independent third-party testing laboratory located within the United States before shipment to confirm the accuracy of their technical specifications (such as TPP, bandwidth). This laboratory must have no financial ties to the exporter or importer and must not be controlled by foreign entities outside the United States. Furthermore, the importing party must implement strict "Know Your Customer" (KYC) procedures and adopt adequate physical security measures, including preventing remote access by Chinese military or intelligence agencies, and prohibiting the unauthorized transfer of trained model weights and algorithms.

Game Theory Logic: Rebalancing National Security and Economic Interests

Behind this series of complex clauses lies a long-standing policy route dispute within the U.S. decision-making circles. On one side, represented by national security hawks, there is concern that advanced chips flowing into China could be used for military purposes, accelerating its militarization of artificial intelligence and thereby threatening U.S. strategic advantages. On the other side, from a more industrial and economic perspective, it is argued that overly stringent bans are a double-edged sword.

Concerns about "innovation being forced." are becoming a reality. The export controls of the past few years have objectively stimulated R&D investment and policy support in China's domestic semiconductor industry. Reports indicate that Chinese authorities have encouraged or even required technology companies to procure a certain proportion of domestic AI chips. If the United States completely cuts off the supply of high-end chips, it will only further force Chinese enterprises to turn to local alternatives. In the long run, this may instead accelerate China's technological breakthroughs in semiconductor design and even manufacturing. To some extent, the Trump administration's current policy adjustment is an attempt to delay this process. By maintaining a certain level of supply, it aims to preserve the penetration and influence of the U.S. technology ecosystem in the Chinese market.

The Power of Corporate Lobbying cannot be ignored. As the dominant player in global AI chips, the Chinese market was once a crucial growth driver for Nvidia. The ongoing export bans have caused it to lose significant potential revenue. The core argument of CEO Jensen Huang's lobbying is precisely to tie business opportunities to "American interests." In its statement, Nvidia claimed that the new regulations are "well-considered, achieving an excellent balance, and are very beneficial to the United States," emphasizing that "American critics are inadvertently promoting the interests of foreign competitors on the entity list." This rhetoric elevates market competition to the level of national industrial rivalry and has clearly found an audience in Washington.

Direct consideration of fiscal interests has also surfaced. According to reports, the Trump administration will impose a 25% surcharge on the sales of approved H200 chip exports. This is both a political gesture, indicating that the tough stance towards China remains unchanged, and a substantial source of fiscal revenue. A Reuters report at the end of December 2025 revealed that Chinese tech companies had ordered over 2 million H200 chips for 2026, far exceeding Nvidia's inventory of 700,000 chips at the time. Even if only a portion of these orders are approved, the surcharge revenue would be considerable.

Market Reaction: The Tug-of-War Between Demand and Substitution

The policy gate has loosened, yet the market's response is not one of unbridled enthusiasm but rather filled with caution and strategic maneuvering.

The Complex Mindset of Chinese Buyers is the primary variable. On one hand, the thirst for high-end computing power is real. In today's era of exponential growth in AI model scale, the H200, compared to the previously export-approved "castrated version" H20 chip, can deliver up to a sixfold performance improvement, which is crucial for training cutting-edge large models. The substantial order intentions already indicate the existence of market demand.

On the other hand, Policy uncertainty and localization pressure are making Chinese companies tread cautiously. Reports indicate that Chinese officials have informed some companies that approval for purchasing H200 chips will only be granted under special circumstances, such as for development labs or university research. Furthermore, it has been reported that Chinese authorities have called on enterprises to suspend H200 procurement while considering mandatory requirements for companies to purchase a certain proportion of domestically produced AI chips. This means that Chinese enterprises face difficult trade-offs between performance, supply chain security, policy compliance, and cost. They desire access to advanced computing power, yet must also consider the political imperative of supporting the local industrial chain, all while navigating the risk of potentially tightening U.S. controls in the future.

NVIDIA's Mixed Feelings. Obtaining the export license is a victory, but the attached stringent conditions severely limit its market potential. The 50% shipment cap, priority supply for the United States, cumbersome review processes, and the 25% sales surcharge all mean that its revenue recovery in the Chinese market will be significantly diminished, with high operational costs. NVIDIA must tread carefully, walking a tightrope between the U.S. government, Chinese customers, and its own global supply chain.

Future Outlook: A Far from Over Enduring Competition

The recent adjustment of the U.S. chip export policy toward China is by no means the end of competition; rather, it marks the beginning of a more complex and dynamic new phase.

The acceleration of technological competition. is an inevitable trend. By setting precise performance thresholds (TPP<21,000), the United States attempts to lock China onto a "sub-advanced" technological track, while reserving a lead window of at least one to two generations for its own next-generation chips (with TPP far exceeding this number). However, the success of this "boiling frog" strategy depends on the pace of China's indigenous innovation. Progress in areas such as chip design (e.g., Huawei Ascend), Chiplet packaging, and computing power network construction in China may enable surpassing the limitations of single-chip performance through different pathways.

The normalization of rule-based gaming. will become the new normal. Future export controls will no longer be a simple matter of "prohibition" and "release," but will evolve into a complex regulatory system based on dynamic performance indicators, supply chain reviews, and end-user verification. Terms such as third-party testing, KYC procedures, and remote access restrictions indicate that technology trade will increasingly be deeply intertwined with issues like data security and algorithm governance. This is not merely a commercial rule but a contest over technical standards and security discourse power.

The Reshaping of Global Supply Chains has far-reaching implications. The U.S. "America First" supply provisions further reinforce the importance of its domestic supply chain. This may prompt technology companies in other regions, in order to ensure their own supply security, to consider diversifying or regionalizing their supply chains, thereby impacting the existing global semiconductor division of labor system. China, on the other hand, will redouble its efforts to build a self-sufficient and controllable industrial chain, even if it initially lacks advantages in performance and cost.

This contest over chips is, at its core, a struggle for control over the infrastructure of the future intelligent era. The recent shift in U.S. policy represents a tactical retreat and realignment, aimed at maximizing its own economic and strategic interests without excessively stimulating China’s independent innovation. It attempts to tie China’s development pace with an "elastic band"—neither allowing it to break free nor letting it stagnate to the point of turning entirely inward.

For China, the limited restoration of external supply may alleviate short-term computing power anxiety, but the strategic direction of **"domestic substitution" shifting from a "backup option" to a "mandatory choice" has become irreversible**. The ultimate outcome of this competition does not depend on the issuance of one or two export licenses, but on who can build a more profound and enduring innovation system in fundamental research, talent cultivation, industrial ecosystems, and engineering capabilities. Chips are merely the surface; the contest of intellect and systems behind them has just entered the deep waters.