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New Export Controls Target China’s Semiconductor Industry

In an effort to restrict China’s ability to purchase and manufacture advanced computing chips, the Bureau of Industry and Security (BIS) issued an interim final rule implementing additional controls on advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items. 

Through this new rule, BIS is:

  1. Expanding end use and end user controls for supercomputer and semiconductor manufacturing items located or destined to China.
  2. Adding prohibitions to the entity list, specifically for 28 Chinese entities.
  3. Expanding scope of foreign produced items that will require a license.
  4. Adding new ECCNs and new ECCN paragraphs to the Commerce Control List.





High-performance ICs


Specified computers, electronic assemblies, and certain components containing 3A090


Software associated with the items controlled in 4A090


Software and technology controls under 3D001 and 3E001

New Paragraph



High-performance ICs


Computers, electronic assemblies not elsewhere specified containing ICs in 3A991.p


BIS is also adding new restrictions on activities of U.S. persons that support the development or production of certain ICs in China. A license will be required for U.S. persons to support the production of the most advanced semiconductors necessary for miliary programs of concern. Per this rule, support is defined as shipping, transmitting, transferring (in-country), or facilitating such shipment, transmission, or transfer of any restricted item to or within China, or servicing any such item.

However, BIS is establishing a Temporary General License to avoid supply chain disruptions for items ultimately destined to customers outside of China.

If you have any questions about these export control changes, or to get more info on how it might impact your business, please contact Allyn at

Contributor: Matthew Dreckman

About Allyn International

Allyn International is dedicated to providing high quality, customer centric services and solutions for the global marketplace. Allyn's core products include transportation management, logistics sourcing, freight forwarding, supply chain consulting, tax management and global trade compliance. Allyn clients range from small local businesses to Fortune 500 firms. Allyn conducts business in more than 20 languages and has extensive experience in both developed and emerging markets. Highly trained experts are positioned throughout North and South America, Europe and Asia. Allyn’s regional headquarters are strategically located in Fort Myers, Florida, U.S.A., Shanghai, P.R. China, Prague, Czech Republic, and Dubai, U.A.E. For more information, visit


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