US–China Chip Controls (2025 Update): What’s Restricted & What Isn’t
A plain‑English guide to 2025 chip controls: what’s restricted, which tools and chips are affected, and where compliance risks hide (cloud AI access, reshipment, and services).
This page summarizes public rules. For legal decisions, consult official regulations and counsel.
2025 snapshot
- AI accelerators: performance‑density thresholds limit high‑end GPUs/accelerators designed for large‑scale AI training.
- Semiconductor tools: advanced lithography, etch, deposition, and metrology subject to licensing; EUV effectively barred; certain DUV lines restricted.
- Design software & IP: EDA tools and advanced IP blocks can require licenses depending on end user and use case.
- Cloud AI access: restrictions on providing AI compute to covered entities even via cloud; verification/KYC duties grow.
- Outbound investment screening: pilot programs target investments in advanced semiconductors and AI.
How the controls work
Entity‑based
Companies or research labs listed on control lists face license requirements across a wide scope (goods, software, tech).
Item‑based
Specific chips, tools, or software meeting technical specs require a license regardless of end user.
Destination‑based
Restrictions apply to shipments to certain countries and to reexports and in‑country transfers.
De minimis & direct‑product rules
Items with controlled US content or built using US tech can fall under US rules even when produced overseas.
Who and what are affected
| Category | Examples | Typical issues |
|---|---|---|
| Chips/Modules | High‑end GPUs/NPUs; advanced networking for AI clusters | Spec thresholds, reseller chains, mixed‑use claims |
| Fab tools | DUV/EUV litho, multi‑patterning, advanced etch/deposition | Service/maintenance, spare parts, field upgrades |
| Software/IP | EDA tools, PDKs, advanced IP cores | Remote access, license transfers, foundry collab |
| Cloud services | Model training/inference at scale | Customer verification, location masking, resold credits |
Compliance checklist
- Map product specs to thresholds; document which SKUs are unrestricted/licensable.
- Screen entities and end uses; require attestations for cloud and design services.
- Control developer access, remote support, and software updates for covered tools.
- Track reexports via distributors; audit high‑risk corridors.
Rules evolve—keep a changelog section at the end of this page.
FAQs
Are mid‑range gaming GPUs restricted?
Controls focus on performance‑density thresholds and datacenter features; many consumer cards aren’t covered but can be scrutinized for data‑center aggregation.
What about repairs and spare parts?
Field service, software keys, and spares for covered tools generally require licensing and end‑use checks.
Can cloud access be used to bypass hardware rules?
Policies increasingly treat cloud compute as an export of capability; providers must verify customers and may need to block certain workloads.
