1. INTRODUCTION
The global race for technological dominance has reached new levels of intensity, with countries competing fiercely to secure control over advanced technologies, particularly semiconductors. These critical components power a vast range of devices, from consumer electronics to complex military systems, making them essential to both economic prosperity and national security. Many nations have adopted unilateral export controls to restrict the transfer of sensitive technology, aiming to limit strategic competitors’ access, especially China. These policies are intended to safeguard national industries and prevent advanced technology from being used in ways that could challenge their own security and industrial standing.
This article examines the evolving landscape of export controls on semiconductors and other advanced technologies, with a focus on measures implemented by the United States, China, Japan, France, Spain, Italy, the United Kingdom, and particularly the Netherlands. It analyses the motivations behind these policies, their implications for global supply chains, and their potential effects on innovation, international economic relations, and the geopolitical balance of power.
a. The Strategic Importance of Semiconductors
Semiconductors are foundational to modern technology, providing essential functionality across a wide array of electronic devices. Beyond consumer electronics, semiconductors are critical to advanced applications in artificial intelligence (AI), telecommunications, autonomous vehicles, aerospace, and defence. As a result, the semiconductor industry has evolved beyond a purely commercial sector to become a central component of national security policies and international competition.
b. The Semiconductor Supply Chain: Interdependence and Vulnerabilities
The semiconductor production process is uniquely complex, involving multiple specialised stages of design, manufacturing, packaging, and testing, each handled in various regions and sites around the globe. Major players like the United States, Taiwan, South Korea, Japan, and the Netherlands dominate specific segments of this supply chain. For instance, the U.S. leads in semiconductor design, while Taiwan and South Korea are leaders in manufacturing, and Japan and the Netherlands supply essential equipment for semiconductor manufacture.
This interdependent supply chain is vulnerable to disruptions, particularly due to geopolitical tensions, economic sanctions and export controls, and natural disasters. By implementing unilateral controls, countries are attempting to mitigate these risks, ensuring that critical components remain accessible, even in times of crisis or heightened international tensions. These controls reflect a desire to prevent potential adversaries from gaining access to technology that could enhance their defence capabilities.
2. U.S. EXPORT CONTROLS: A TOOL OF STRATEGIC COMPETITION
In the early 2000s, integrating China into the global economy was viewed as a strategic move by both the Clinton and Bush administrations, with the belief that economic interdependence would foster stability and mutual growth. However, China leveraged this economic engagement to strengthen its defence industry through its “Military-Civil Fusion” plan, using civilian tech, much of it from U.S. partners, for military advancement. Over time, the U.S. began viewing technological ties with China as vulnerabilities, while recognizing its ability to exploit this interdependence to gain strategic leverage.1
The U.S. capitalizes on its dominance in chips design (process of producing an implementation ready to be laid out into a chip). With the U.S. and its allies producing over 90% of the world’s semiconductor equipment, China remains heavily reliant on foreign imports. The Biden administration has used this advantage to slow China’s progress, especially in artificial intelligence (AI), employing a “small yard, high fence”2 strategy to target critical supply chain areas, like advanced lithography tools and AI chips, while minimizing broader economic disruptions.3
While China’s semiconductor industry has been severely impacted by export controls, with output falling 17% in early 2023, significant gaps remain in enforcement. After the U.S. introduced export controls October 2022, some companies modified their products to comply with new restrictions, but as controls tightened in 2023, adapted again by introducing new AI chips tailored for China.4 Another issue is the use of cloud platforms, allowing Chinese firms to bypass restrictions and access powerful U.S. chips.5
Attempts to circumvent sanctions imposed on advanced chips are also a growing concern, with reports of entire servers, containing top-tier chip being trafficked on the black market.6
After a chip manufactured by a Taiwan-based manufacturer was found inside a Huawei processor, the U.S. ordered the company to halt shipments of advanced chips to Chinese customers that are often used in artificial intelligence applications.
a. The Entity List: A Targeted Approach to Restricting Technology Access
One of the primary tools employed by the U.S. is the Entity List, managed by the Bureau of Industry and Security (BIS). Companies on this list, such as Huawei and Semiconductor Manufacturing International Corporation (SMIC), are barred from accessing American technology and components, significantly impacting their ability to innovate and compete in the global market. By restricting access to high-end chips, software, and other essential technologies, the U.S. has disrupted China’s tech industry, forcing it to explore alternative sources and accelerate domestic innovation.
A unilateral approach to export controls may encourage US to make full use of the Foreign Direct Product Rules (FDPR). This rule implements statutory authority for the United States to control a product extraterritorially – even those that are fully manufactured in a foreign country – if the product utilizes certain U.S.-origin technology. Since U.S. companies are critical to many parts of the semiconductor supply chain, much of the world’s chipmaking industry is covered.
The use of FDPR has two major downsides: political backlash and limitations. First, extraterritorial control alienates U.S. allies, harming long-term alliances. Second, companies can bypass U.S. restrictions by adjusting their supply chains to exclude U.S. components. While FDPR offer significant authority, they must be used cautiously to avoid negative consequences for both diplomacy and industry. If the U.S. overcomplicates regulations, it could drive the creation of alternative supply chains, diminishing its influence without yielding any benefits.7
b. The CHIPS and Science Act: Rebuilding U.S. Manufacturing
In addition to external restrictions, the U.S. has implemented domestic initiatives like the CHIPS and Science Act, a $52 billion project aimed at boosting semiconductor manufacturing within the country. This act provides incentives for companies to establish new manufacturing facilities in the U.S., reducing dependence on foreign suppliers. This policy is expected not only to enhance national security but also to create jobs, stimulate economic growth, and address vulnerabilities in the semiconductor supply chain by localizing more production processes.
To maintain a robust industrial base, it’s essential to limit controls to the most critical and effective instances. A prime example of this is the regulation of extreme-ultraviolet (EUV) photolithography machines. Produced exclusively in the Netherlands, these machines are hard to replicate, difficult to smuggle, and vital for advanced semiconductor production. The U.S. successfully pressured the Netherlands to prevent EUV exports to China, in an attempt to maintain a strategic technological advantage over the Eastern superpower. However, tightening controls on other chipmaking tools could backfire, as these products are often easily sourced or reproduced elsewhere, reducing the effectiveness of the controls.8
3. CHINA’S RESPONSE TO U.S. EXPORT CONTROLS
Facing increasing U.S. restrictions, China has responded by accelerating efforts toward self-sufficiency in semiconductors and other advanced technologies. The Chinese government has allocated substantial resources to fund semiconductor research and development, aiming to reduce its reliance on foreign technology and enhance resilience against external pressures.
a. “Made in China 2025″ and Domestic Innovation
“Made in China 2025”, an initiative launched by the Chinese government, aims to establish China as a global leader in high-tech industries, including semiconductors. Through subsidies, tax incentives, and strategic investments, China has been developing its semiconductor manufacturing capabilities. However, despite significant investments, the country remains dependent on foreign technologies in areas such as semiconductor design and advanced fabrication. The country faces substantial obstacles, particularly in acquiring highly specialized machinery for cutting-edge semiconductor production.9
To bridge the gap, China also adopted in 2023 the New Quality Productive Forces policy (NQPFs)10 which sets out an innovation-led economic growth model wherein emerging technologies give rise to a new array of industries and economic models. NQPFs also serve the purpose of transforming traditional industries, modernizing them through processes such as digitization, connectivity, and smart upgrades.
The 2023 policy, details a range of specific support measures aimed at advancing computing power, set to be implemented by April 2029. These measures include subsidies of up to 1.41 million U.S. dollars for the construction of new intelligent computing centers, green intelligent computing projects, the purchase of autonomous intelligent computing chips, and computing power rental expenses for large model development. Additionally, technological innovation vouchers will be provided to technology-based SMEs.11
b. Chinese Export Controls on Rare Earths
In response to U.S. export controls, China has imposed restrictions on rare earth elements, materials essential for many high-tech components, including semiconductors. China controls a large share of the global supply of these materials, which allows it to use this resource as leverage within global supply chains. This strategy underscores China’s approach to counterbalancing U.S. policies, using its economic influence to protect its interests while maintaining leverage in a highly competitive market.12
c. Taking advantage of loopholes
Chinese entities, including some with military connections, have reportedly sought to bypass U.S. restrictions by utilizing cloud platforms. This enables them to access advanced chips, without directly owning the hardware. Even companies listed on the US Entity List have managed to obtain powerful computing resources via the cloud. For instance, concerns have been raised that a Chinese AI company blacklisted for human rights violations, had legally rented high-performance chips through cloud services despite sanctions.13
Although an estimated 10,000 chips are smuggled into China each year, this number alone is not particularly alarming given that global tech companies use millions of chips annually. However, what is more concerning is the reported trafficking of entire servers (equipped with eight high-end chips) on the black market, suggesting the emergence of more sophisticated smuggling operations. Industry experts fear that such networks could expand significantly in the future.14
To combat these threats, some cybersecurity professionals have recommended equipping server racks with global positioning system (GPS) trackers to monitor their location and usage. Additionally, the US government has reportedly considered implementing stricter reporting requirements for cloud service providers to prevent sanctioned entities from accessing restricted technologies. These measures would help address the existing gaps in the enforcement and evasion of export controls.15
4. STRENGTHENED EXPORT CONTROL POLICIES AMONG THE ALLIES
a. Japan’s Targeted Controls on Semiconductor Equipment
On May 23, 2023, Japan introduced METI Order No. 25, which updates its export control regulations by adding over twenty types of semiconductor production equipment to the list of items subject to list-based controls, rather than the broader catch-all controls. These newly controlled items include equipment used for advanced semiconductor production, such as extreme ultraviolet (EUV) and argon fluoride (ArF) immersion lithography, EUV mask inspection, and various cleaning, deposition, and etching processes. The controls also cover EUV pellicles, along with certain software programs designed to operate these specialized machines. Additionally, related components, accessories, and technologies used to design or manufacture the controlled equipment, excluding software programs and process design kits, are now subject to these export restrictions.
Effective July 23, 2023, exporters will need to obtain a license to export the newly controlled semiconductor production equipment and related items from Japan to any destination. Exporters can apply for individual export licenses, which will be reviewed by METI on a case-by-case basis. Alternatively, depending on the export destination, they may be eligible to use one of Japan’s existing bulk licenses, such as the General Bulk License, Special General Bulk License, or Specific Bulk License.16
b. The United Kingdom’s Regulatory Adaptations
On 11 March 2024, the UK expanded its export control regime to include new controls on specific emerging technologies, such as quantum computing, semiconductor technologies and additive manufacturing, under The Export Control (Amendment) Regulations 2024 (the ECO 2024). The new controls came into force on 1 April 2024. The UK’s recent policies target dual-use and emerging technologies, such as AI and quantum computing. Through its Export Control Joint Unit (ECJU), the UK screens exports rigorously to ensure they do not contribute to military applications in potentially adversarial nations. The UK’s strategy includes safeguarding intellectual property, balancing national security with research needs, and supporting broader allied security objectives.17
c. Strengthened Export Control Policies in EU
Across Europe, individual countries have adopted export controls in advanced technology sectors, complementing the European Union’s collective efforts under the European Chips Act. France, Spain, and Italy have each introduced targeted regulations to address national security concerns while aligning with EU-wide measures.
1) France: Expanding Controls on Dual-Use Technologies
On 2 February 2024, the French government enacted the Decree of 2 February 2024 (the Decree), introducing national controls on goods and technologies associated with quantum computing and advanced semiconductor components.18 This Decree is based on Article 9(1) of Regulation (EU) 2021/821 (the EU Dual-Use Regulation), which allows EU member states to restrict or require authorization for the export of certain dual-use items not included in Annex I of the regulation for reasons of public security, including anti-terrorism measures or human rights considerations. These new French regulations, therefore, add layers beyond the existing controls established by the EU Dual-Use Regulation.
In essence, exporting goods, software, and technologies listed in the Decree’s Annex from the EU will now require specific authorization from French authorities.
The items subject to the new authorization requirements include two categories also covered by recent UK unilateral controls:
Certain semiconductor technologies and equipment (excluding semiconductor materials and some production equipment covered by UK regulations).
Quantum computing technologies.
Unlike the recent UK regulations, the French unilateral controls do not cover additive manufacturing technologies. However, as with the UK regulations, “software” and “technology” associated with the development or production of these covered hardware technologies are also subject to control.
From 1 March 2024, exporters must obtain a license from the French dual-use authority, the “Service des biens à double usage” (SBDU), to export the above-listed items from France to non-EU countries. Companies involved in advanced technology and quantum sectors must now evaluate the implications of these controls on their operations and supply chains.
Furthermore, the enhanced focus on quantum technologies reflects the French government’s increasing concerns regarding the regulation of advanced technologies, highlighted by the broad scope of controls covering essential components for quantum computing. This emphasis aligns with the EU’s Economic Security Strategy, which seeks to protect international security by prudently managing dual-use technologies.
2) Spain: Emphasis on Cyber-Surveillance and AI Technologies
On 7 June 2023, the Spanish government updated Annex III.5 of Royal Decree 679/2014 (the Decree), specifying items subject to export licensing that are not included in Annex I of the EU Dual-Use Regulation. Like the additional controls introduced in France, the Spanish regulations are grounded in Article 9(1) of the EU Dual-Use Regulation, which permits EU member states to impose export licenses on specific items for reasons of public security or human rights concerns. The updated Decree now requires licensing for identified items.
Annex III.5 of the Decree specifically adds export control requirements for a subset of categories also covered in the UK regulations, including:
- Certain semiconductor production equipment, particularly scanning electron microscopes designed for imaging semiconductor devices or integrated circuits, and dry etching equipment, as covered by both UK and French regulations;
- Certain semiconductor technology, particularly for developing or producing integrated circuits using gate envelope field-effect transistor (GAAFET) structures, a category also covered by the UK and French regulations;
- Quantum computing technologies;
- Certain additive manufacturing equipment designed or modified to produce explosive, pyrotechnic, or propellant devices from energetic materials (not covered by the UK and French regulations).
Under this Decree, exporters must secure a license from the Spanish General Directorate of International Trade of Military and Dual-Use Items to export the specified items in Annex III.5 from Spain to non-EU countries.
As with the recent UK and French regulations, the Spanish Decree also controls software and technology related to the development or production of these covered hardware technologies.19
3) Italy: Targeted Controls on Advanced Computing and Telecommunications
On July 1, 2024, the Italian Ministry of Foreign Affairs issued a Decree establishing a National Control List for dual-use goods and technology not included in Annex I of the EU Dual-Use Regulation. This new list adds additional controls that go beyond the requirements of the EU Dual-Use Regulation.
For the items listed, the Italian government has introduced unilateral authorization requirements, not only for exports from Italy to non-EU countries but also for brokering services and technical assistance related to these items.
The products included in the National Control List cover goods and technology in Category 2 (Materials processing), Category 3 (Electronics), and Category 4 (Computers).20
4) The Netherlands’ Expanded Export Restrictions on Semiconductor Technology
The Netherlands plays a pivotal role in the semiconductor industry due to ASML, a leading manufacturer of lithography machines essential for producing advanced chips. ASML’s EUV (Extreme Ultraviolet) lithography technology, considered the most advanced in the world, is critical for creating high-performance semiconductors for various applications, from consumer electronics to defence.
Since June 2023, Dutch authorities have introduced specific export control measures targeting critical technologies such as advanced semiconductor manufacturing equipment. As they are measures that go beyond the legislation enacted by the EU, these measures are typically referred to as national export controls.21
With the Ministerial Decree, the Dutch government imposed national export control measures for advanced SME, which leads to certain advanced SME becoming subject to a Dutch export authorization requirement, thereby creating a de facto export prohibition for certain advanced SME to China without explicitly mentioning China in the Ministerial Decree. That China is not explicitly mentioned can easily be explained as a calculated effort by the Dutch government to prevent any further geopolitical repercussions and tensions between the Netherlands and China.
With this country-neutral regulatory framework, the Ministerial Order clearly reflects the result of the Dutch government being placed between a rock and a hard place. On one side, the Dutch saw the US Foreign-Direct Product Rule dangling over the bilateral talks, which the United States used to strong-arm the Netherlands into a deal. On the other, the Dutch did not want to antagonize China as the world’s second-largest economy any further and, as such, did not want to introduce any controls that were not country-neutral, without the usual backing of other member states of the European Union.
On 18 October 2024, the Ministry of Foreign Affairs of the Netherlands published the Decree of the Minister for Foreign Trade and Development of 11 October 2024, no. BZ2405833 introducing a licensing requirement for the export of certain products not listed in Annex I to Regulation 2021/821 (Decree on additional control measures to the Dual-use Regulation).
The recent Decree is a continuation and expansion of the export control measures on semiconductor manufacturing equipment introduced by the Netherlands on 30 June 2023 and 7 September 2024 and now includes quantum computing and additive computing goods.
The measures were adopted based on EU and Dutch law:
As mentioned above, article 9(1) of Regulation (EU) 2021/821 of the EU Dual-use Regulation allows Member States of the EU to “prohibit or impose an authorization requirement on the export of dual-use items not listed in Annex I for reasons of public security, including the prevention of acts of terrorism, or for human rights considerations.”
Article 4 of the Dutch Strategic Goods Decree (BWBR0024139) provides that “[b]y ministerial decree, [the Minister] may, for reasons of public security or human rights considerations, impose a ban on, or require a license for, the export of dual-use goods not listed in Annex I of the Dual-use Regulation.”
In the explanation accompanying the Decree, the Minister for Foreign Trade and Development (the “Minister”) noted that the primary rationale behind this Decree, like the previous ones, is national and international security concerns.
The Minister deems that the uncontrolled export of these goods from the Netherlands to destinations outside the EU may pose risks to public safety, including international peace and stability. The Minister also cites the international nature of the goods flow and the Netherlands’ position in the value chain as justifications for these additional export control measures.
In response to increasing concerns over national and international security, the Dutch government has introduced a new set of export control measures specifically targeting sensitive technologies in the semiconductor, quantum, and additive manufacturing sectors. Starting from December 1, 2024, Dutch companies must apply to the Minister for export licenses to send these newly controlled goods and technologies to entities outside the EU.
To comply with these new controls, companies can apply for either a global export license (permitting exports to one or more recipients across multiple non-EU countries) or an individual export license (valid for exports to a single recipient in a non-EU country). Applications must provide comprehensive details about the items, the recipient, the intended end-use, and the end-user. In some cases, authorities may request additional documentation, such as contracts, technical specifications, or an end-use declaration.
For global export licenses, applicants must implement an Internal Compliance Program (ICP) under Article 12, paragraph 4 of the Dual-use Regulation. This ICP is intended to establish effective, proportionate due diligence policies and procedures, ensuring that companies adhere to the provisions and objectives of the Dual-use Regulation.
The Netherlands has also introduced a National General Export License (NL900), designed to simplify compliance. Under specific conditions, this license allows for exports to certain non-EU destinations, including Australia, Canada, Iceland, Japan, New Zealand, Norway, Switzerland, Liechtenstein, the United Kingdom, and the United States. This new license structure aims to streamline the process for affected industries, reducing the administrative burden while maintaining strict oversight on sensitive exports.22
d. A new way to impose export controls
On 20 October the European Commission published for the first time in the Official Journal of the European Union a compilation of national control lists in application of Article 9(4) of the EU Dual Use Regulation.23
This inedited list opens the doors to promoting coordination between Member States and approach to export controls in a new way, at a time of heightened awareness of critical security concerns.
If a particular EU member state has not implemented similar legislation, an export license would generally not be required to transfer items listed under the French, Spanish, Italian or Dutch national control lists. However, an exception arises if the competent authority of that member state informs the exporter that the item in question is, or could be, intended for use in ways that raise public security or human rights concerns. In such cases, an export license would be necessary, and it should be obtained from the member state where the export takes place, even if that state lacks specific national legislation requiring such a license.
Under Articles 9 and 10 of the EU Dual-Use Regulation, the competent authority of any EU member state can enforce an export license requirement based on another member state’s legislation once it is published in the EU’s Official Journal (as was the case with national control lists published in October 2023), especially when there are concerns about the item’s end use. Consequently, these new national controls may also impact exports from EU member states beyond France, Spain, Italy and the Netherlands.24
5. THE EUROPEAN CHIPS ACT: A STRATEGIC INITIATIVE FOR SUPPLY CHAIN RESILIENCE
In response to the global semiconductor shortage and growing geopolitical tensions, the European Union launched the European Chips Act in 2022. This ambitious initiative aims to enhance the EU’s semiconductor self-sufficiency, reduce dependency on foreign suppliers, and strengthen Europe’s resilience against external supply chain shocks.
The European Chips Act includes substantial funding—€43 billion in public and private investment—with the goal of increasing Europe’s global market share in semiconductor production to 20% by 2030. The Act focuses on creating a robust ecosystem for chip design, manufacturing, and research, supporting both established companies and startups. This initiative not only aims to advance Europe’s technological capabilities but also serves as a long-term strategy to enhance supply chain security and maintain competitiveness in an industry dominated by the United States and Asia.25
One of the key components of the Act is the establishment of “European Semiconductor Innovation Centers”, designed to foster collaborative research and development across the semiconductor ecosystem. By promoting innovation in areas such as AI chips and next-generation computing, the EU intends to secure a leadership position in the technology landscape. Additionally, the Act includes provisions for rapid-response mechanisms, enabling EU nations to address semiconductor supply chain disruptions swiftly during crises.
The implementation of the EU Chips Act is leading to significant collaborations with foreign partners, especially U.S. companies and Taiwan’s TSMC. For example, Intel has announced plans to invest $88 billion in expanding its chip research and manufacturing facilities in Europe. In 2023, Intel secured nearly $11 billion in subsidies from the German government for a chipmaking facility in Magdeburg, with Intel contributing €30 billion to the project. Intel is also investing €12 billion in Ireland to expand its manufacturing space and $4.6 billion in Poland for an assembly and test facility. Additionally, Intel is involved in chip projects in France, Italy, and Spain.
U.S.-based GlobalFoundries and STMicroelectronics received approval from the European Union for French government subsidies totalling $8.13 billion to build a chip fabrication plant in Crolles, France, while GlobalFoundries is expanding its facilities in Dresden, Germany. U.S. chipmaker Wolfspeed plans to invest $3 billion in a silicon carbide chip plant in Germany, with the German government expected to provide 20% of the funding.
In August 2023, Infineon, Bosch, TSMC, and NXP Semiconductors announced plans to create the European Semiconductor Manufacturing Company in Dresden, with TSMC taking the majority stake. The project, valued at €10 billion, will receive strong support from the EU and the German government. Infineon also plans to build a €5 billion semiconductor manufacturing facility in Dresden and is seeking €1 billion in public funding.
Additionally, the EU has approved €292.5 million in grants to STMicroelectronics for a silicon carbide semiconductor plant in Catania, Italy. The Chips JU is also offering €325 million in research funding to support chip innovation, including the creation of competence centers to assist small and medium enterprises26
6. CONCLUSION: TOWARD A SUSTAINABLE APPROACH IN EXPORT CONTROLS
Western semiconductor export controls could have significant and unexpected effects on both the US/EU and China. American and European chipmakers could face substantial financial problems due to their loss of access to the Chinese market. According to the US Chamber of Commerce in China, this could result in annual losses of $83 billion in sales and the elimination of 124,000 jobs.27
Semiconductor equipment companies, which heavily rely on China, are especially vulnerable, with a large percentage, up to 40%, of their revenue coming from Chinese customers. This shift is evident in companies like SMIC, which has moved from 60% foreign production to 80% domestic production in recent years.28
These export restrictions could accelerate China’s drive to become more self-sufficient in semiconductor manufacturing. By restricting access to affordable foreign chips, Western policies might push Chinese companies to focus more on developing domestic solutions.
This shift could allow China to invest in alternative technologies, such as memory-focused computing and system-level optimizations, which could help it reduce the technology gap with the US, even without access to advanced chip-making machines. In this way, China could circumvent US sanctions and weaken their overall effectiveness.
The global landscape of export controls on advanced technology is becoming increasingly complex, with more and more states starting to implement policies to secure their strategic interests. The addition of UK controls highlights the importance of a coordinated approach across allied nations, particularly as technological advancements blur the lines between civilian and military applications. While unilateral measures provide immediate advantages, they risk creating fragmentation within the global market, raising costs for international industries that rely on interconnected supply chains.
For long-term stability, multilateral agreements may be necessary to create a more balanced export control system. Through frameworks like the Wassenaar Arrangement, nations could work together to create rules that secure sensitive technologies without hindering innovation. The future of the semiconductor industry and other advanced technology sectors depends on the ability of nations to find a middle ground, fostering global collaboration while protecting national and collective security interests.
Footnote(s):
[1] U.S. Department of State, The Chinese Communist Party’s Military-Civil Fusion Policy
[2] ‘Global Times, High fence, small yard’ approach forces the world to ‘de-Americanize‘
[3] Foreign Policy Research Institute, Breaking the circuit: US-China Semiconductor
[4] Techwire Asia, Nvidia unveils China-compliant gaming chip amid US export controls
[6] The Wall Street Journal, The Underground Network Sneaking Nvidia Chips Into China
[7] The Diplomat, Why US Semiconductor Export Controls Backfire
[9] Foreign Policy Research Institute, China’s Defiant Chip Strategy
[11] China Briefing, China’s New Quality Productive Forces: An Explainer
[13] Foreign Policy, Chinese Firms Are Evading Chip Controls
[14] ChinaTalk, Smuggling A100s + Biden and Shakespeare
[15] Bloomberg, US Wants Cloud Firms to Flag Foreign Users in China AI Race
[16] Ministry of Economy, Trade and Industry (METI) Order No. 25 of 2023
[17] The Export Control Order 2024
[19] Royal Decree 679/2014, Annex III.5
[21] Regulation on Advanced Production Equipment for Semiconductors
[22] Decree of the Minister for Foreign Trade and Development of 11 October 2024, no. BZ2405833, see also Bennink Dunin-Wasowicz Insight, The Netherlands expands National Export Control Measures Affecting the Semiconductor, Quantum Computing and Additive Manufacturing Services (30 October 2024)
[24] Regulation EU No 821/2021, Articles 9 and 10
[25] European Commission, The EU Chips Act
[27] U.S. Chamber of Commerce, Understanding U.S.-China Decoupling: Macro Trends and Industry Impacts
[28] Center for Strategic & International Studies, Legacy Chip Overcapacity in China: Myth and Reality