The United States adjusts chip export controls, related to lithography machines, RTX4090, and AIPC

It is understood that the new export control regulations will take effect on April 4, and the U.S. Department of Commerce defines this revision as "correcting unexpected errors and clarifying some terms."

This update can be roughly summarized into two categories: new additions and modifications, including the addition of control over manufacturing equipment such as EUV masks and etching machines, and the addition of "presumptive rejection" for Macau, China and D:5 group areas. "policy, as well as re-clarification of the scope of application of the AI ​​chip license and its exceptions, etc.

It has been updated and adjusted several times in three years, and the time interval has been shortened from one year to six months. This combination is the first in the history of the U.S. Department of Commerce. Its purpose is also very clear - to restrict the leapfrog of China's semiconductor industry to advanced technology and to restrict the Chinese technology industry's access to high-performance chips, which is a "stuck neck" in the popular sense.

Macao region was mentioned 69 times

The Macau region was also mentioned in the previous export control regulations, but this time it was mentioned particularly frequently in the revision. According to rough statistics, it was mentioned 69 times in the entire text.

This regulation continues the October 2023 rules, that is, relevant enterprises will adopt a "presumptive rejection" strategy when exporting products to the Macao region, or to customers in D:5 group countries and regions through the Macao region.

How to understand it?

If Nvidia and AMD export controlled AI chips to these regions in the future, regular applications will be rejected by default without special reasons. This policy has actually been implemented since last year.

Some people may be curious about what Group D:5 is, which involves the "Country Group List" in US export control - this list divides different countries and regions into four groups A\B\D\E, where A represents multilateral Organizations are "American partners" in the usual sense. Group B directly delineates a group of countries and regions and is a less restricted subject. Group D and E can be deduced based on their closeness and distance. Each group is divided into different control reasons. The aforementioned D:5 is the fifth type of control corresponding to group D. This group covers more than 20 countries and regions such as China, Iran, and Russia.

Generally speaking, different groups have different priorities for controlled items and license issuance.

In addition, this update also adds a license exemption description called "Advanced Computing Authorized" - if it is not exported to Macau, China, countries and regions in the D:4 and D:5 groups, no Additional license required - covers ECCN codes such as 3A090, 4A090, 3A001.z, 4A003.z, 4A004.z, 4A005.z, 5A002.z, 5A004.z, 5A992.z, 5D002.z and 5D992.z s project.

"4090" and AIPC saved

Although this kind of rigid requirement is more clear in terms, it is very "lethal". Customized products of specific companies targeting the Chinese market, such as Nvidia's H800\A800, cannot be exported due to performance density issues, and even some Consumer products, such as RTX4090, have also been affected.

Therefore, this time BIS also clearly mentioned in the control regulations that the "digital computers", "electronic components" and related equipment and "components" mentioned in category 4A003.c, except for groups E:1 and E:2 For destinations other than countries and regions, no license is required as long as the "adjustable peak performance" does not exceed 70TFLOPS.

At the same time, the revised regulations also mention that if the performance mentioned in category 3A090.a is not exceeded, it can be reviewed on a case-by-case basis to determine whether to issue a license. In the previous version, according to the regulations Unable to obtain permission.

More detailed control of photolithography machines

U.S. business will naturally consider this issue, so in this update to the export control regulations, it is mentioned that if the relevant equipment can achieve the performance of the controlled equipment, it needs to be reviewed and approved on a case-by-case basis.

Overall, this update does not mention much about lithography equipment and technology. This is mainly because the previous version has strictly explained some core technical indicators, including DUV with a wavelength of 193nm and a resolution of less than 45nm. The minimum proportion rule for equipment has been modified, requiring relevant equipment to be subject to US control as long as it contains more than 0% controlled items. There are also clear restrictions on the DCO value of the overlay accuracy of the photolithography machine. If it is less than or equal to 2.4nm, it needs to be controlled (previously it was 1.5nm).

In this update, lithography is mentioned a total of 17 times in the full text. The equipment part focuses more on the revision of parameters, including specific dimensions, temperature, pressure, etc. , such as dedicated for aluminum, gallium, indium, arsenic A metal-organic chemical vapor deposition reactor developed for the epitaxial growth of two or more compound semiconductors among phosphorus, antimony or nitrogen, which means that the control of semiconductor equipment extends from semiconductors represented by silicon to the field of compound semiconductors.

As we mentioned earlier, the U.S.’s export controls on China are continuously dynamic. There is another potential signal in the control regulations. The control standards for some specific equipment are described as “reserved”, which means I will not write about it here. , wait until there are new changes in technology in the future, and revise and update again.

It is worth mentioning that in this update, BIS has added an ECCN code of 3B001.j to control EUV masks, related software and technology , and the control reasons have added "national security" and "regional stability" , Exports and re-exports to Macau, D:5 countries and regions require application for licenses, but the impact on China-related equipment will not be significant in the short term.

In contrast, restrictions on equipment and components including etching machines, thin film deposition and other equipment have further put a "tightening curse" on China's chip manufacturing. In order to strengthen the control effect, this revision also highlights the end-use control of manufacturing equipment, focusing on When it comes to indirect exports, re-exports, and domestic transfers to Macau, China or D:5 countries and regions, simply put, it means to prevent equipment from changing hands multiple times to circumvent controls. Therefore, BIS also made it clear that this action is aimed at the problem of original equipment manufacturers and others still pushing for order delivery even though they know the end use.