Intellectual History of U.S.-Led Semiconductor Export Controls Targeting China

Thanks for the detailed clarification. I’ll put together an intellectual history of the arguments for U.S.-led semiconductor export controls on China, focusing primarily on the post-2018 era but including earlier context where relevant. I’ll examine arguments from government officials, think tanks, academics, and industry figures, while emphasizing official U.S. statements. The rationale will be categorized by economic and national security concerns, with attention to how goals have evolved over time. I’ll also include key moments of international coordination with U.S. allies where relevant. I’ll let you know as soon as the research is ready.

Intellectual History of U.S.-Led Semiconductor Export Controls Targeting China (2018–Present)

President Biden holding a semiconductor chip while discussing supply chain security in early 2021. U.S. policymakers have increasingly viewed advanced chips as critical strategic assets, linking them to national security and economic competitiveness.

Introduction

The United States has progressively tightened export controls on semiconductors and related technology to China, especially from 2018 to the present. This report traces the evolution of these controls, including earlier foundations, and examines the shifting justifications offered by U.S. government agencies, think tanks, academics, and industry stakeholders. What began as targeted measures aimed at specific national security risks has broadened into a comprehensive strategy to maintain U.S. technological superiority in advanced computing and artificial intelligence (AI). Key rationales – spanning national security, economic competitiveness, and technological leadership – have been emphasized to varying degrees over time. We present a timeline of major policy developments, highlight the arguments and proposals from influential voices, and assess whether the U.S. has achieved its initial goals (such as slowing China’s military AI progress and preserving a technology lead) or redefined those goals as circumstances changed. Clear headings, a timeline of events, and summary tables are provided for ease of reference.

Background: Foundations of Export Controls and China’s Tech Ambitions (Pre-2018)

U.S. export controls on advanced technology are not new – they have Cold War origins and were retooled after the Tiananmen Square sanctions of 1989 to bar arms sales to Chinasgp.fas.org. By the 1990s and 2000s, however, many dual-use technology exports to China were liberalized in line with globalization and U.S. business interestssgp.fas.orgsgp.fas.org. This enabled China to import vast amounts of U.S. high-tech components with minimal restrictions. Meanwhile, China undertook state-led initiatives to reduce dependence on foreign technology and achieve leadership in strategic sectors. Notably, the Made in China 2025 industrial plan (launched in 2015) set ambitious targets to dominate industries like semiconductors, AI, aerospace, and robotics, often by leveraging foreign technologysgp.fas.org. In parallel, China’s Military-Civil Fusion (MCF) policy sought to ensure that advancements in “civilian” high-tech (often acquired from abroad) directly supported the Chinese militarysgp.fas.org. U.S. officials and experts grew concerned that China’s approach was blurring the line between civilian and military end-uses, complicating traditional export control distinctionssgp.fas.org. By the late 2010s, it was evident that China’s rapid progress in supercomputing, AI, and telecommunications (sometimes aided by illicit acquisition of U.S. know-howbidenwhitehouse.archives.gov) could eventually threaten U.S. technological and military advantages. This context set the stage for a significant tightening of U.S. export control policy toward China.

Timeline of Key Policy Developments (2018–2023)

2018 – Turning Point: The U.S. government began overhauling its export control framework in response to China’s tech rise. In August 2018, Congress passed the Export Control Reform Act (ECRA) as part of the National Defense Authorization Act. ECRA reestablished the President’s broad authority to control “emerging and foundational technologies” for national security, and mandated identifying critical cutting-edge tech (like advanced semiconductors and AI) that should be regulatedsgp.fas.orgsgp.fas.org. This legislative change reflected bipartisan alarm that Beijing’s drive for tech leadership (and reports of intellectual property theft) could erode U.S. security and economic primacy. Also in 2018, the impact of export controls became starkly clear when the Commerce Department’s Bureau of Industry and Security (BIS) imposed a denial order on Chinese telecom firm ZTE, cutting off its access to U.S. chips. ZTE’s operations nearly collapsed, underscoring U.S. leverage over Chinese tech firms dependent on American components. Although the ZTE ban was later lifted after fines and agreements, it foreshadowed the coming “tech decoupling.” Around the same time, U.S. authorities brought charges against Chinese state-backed chip company Fujian Jinhua for stealing memory chip designs, and moved to block its access to U.S. technologywww.reuters.comwww.reuters.com. These actions sent an early signal that advanced semiconductor know-how was now viewed through a national security lens.2019 – Entity List Expansion and Initial AI Chip Restrictions: In 2019, the Trump Administration steadily expanded the use of the Entity List, a tool to restrict specific foreign companies from receiving U.S. exports without a licensesgp.fas.org. In May 2019, Chinese telecom giant Huawei and dozens of its affiliates were added to the Entity List, citing national security concerns (Huawei was accused of facilitating espionage and had close ties to the state). This move “effectively cut off Huawei’s access to key U.S. semiconductors” and other inputswww.csis.orgwww.csis.org. U.S. chipmakers could no longer supply Huawei freely, disrupting Huawei’s smartphone business and its ability to source advanced chips for 5G network gear. The official rationale focused on telecommunications security and potential military uses, but it also carried economic overtones (preventing China from overtaking in 5G). Beijing decried the blacklisting as unjustified, while U.S. think tanks like CSIS noted it reflected a “growing policy consensus” on the need to get tough on Chinese tech firmswww.csis.org. Separately, in late 2019, the Commerce Department began denying licenses for certain AI-related chip exports to China. For example, U.S. firms were barred from selling leading-edge GPU accelerator chips to specific Chinese supercomputing centers implicated in nuclear weapons research or surveillance. These early curbs were relatively narrow, targeting clearly military-linked end users (e.g. China’s National Supercomputing centers and companies like Sugon) to “deny China direct and significant military benefits” from U.S. techsgp.fas.org. Still, they signaled a broader concern that advanced AI chips and high-performance computing (HPC) could enhance China’s military AI development or repression apparatus (e.g. AI-driven surveillance of minority populations).2020 – Tightening the Noose (Military End-Use Rules and Foreign Direct Product Rule): By 2020, U.S. export control policy explicitly linked advanced semiconductors to national security in new ways. In April 2020, the Commerce Department eliminated civil-use license exceptions for exports to China, Russia, and Venezuela, expanding the scope of items requiring licenses when destined for military end-users in Chinawww.piie.com. This Military End-Use rule expansion meant even relatively common electronics could be restricted if going to a company with any tie to China’s military, reflecting the reality of MCF. Then in May and August 2020, the U.S. dramatically expanded the Foreign Direct Product Rule (FDPR) to further choke off Huawei’s access to semiconductors. Under the FDPR extension, foreign-made chips that were produced using U.S. software or equipment (ubiquitous in chip fabrication) were now subject to U.S. licensing if aimed at Huaweiwww.cnas.org. In essence, Washington applied its controls extraterritorially, leveraging U.S. dominance in chip design tools and manufacturing gear to block Huawei from getting advanced chips made by third parties like TSMC in Taiwanwww.cnas.org. This was a novel use of U.S. regulatory power; it illustrated what some analysts termed “weaponizing interdependence” – akin to how the U.S. uses its financial clout via the dollar, but now applied to tech supply chainswww.cnas.orgwww.cnas.org. While aimed at a single company, this set a precedent for broader semiconductor controls. Industry stakeholders grew uneasy as China was a major market – U.S. semiconductor exports to China hit record levels in 2020 even amid the trade warwww.congress.gov. Nonetheless, national security officials justified the measures as necessary to prevent cutting-edge U.S. chips from advancing China’s military communications and AI-enabled surveillance state. In the short term, Huawei’s ability to produce advanced smartphones and 5G base stations was indeed crippled, one of the first clear outcomes of the export control offensive. In another notable 2020 action, SMIC (Semiconductor Manufacturing International Corp) – China’s leading chip fab – was added to the Entity List in December, on the grounds that its chips might go to Chinese military systems. These steps reflected a widening view that entire segments of China’s semiconductor sector (design, fabrication, and supercomputing) were intertwined with security concerns.2021 – A New Administration and Strategic Reviews: The Biden Administration took office in January 2021 and largely continued the tough line on tech exports to China, while conducting reviews to formulate a unified strategy. In March 2021, the congressionally-mandated National Security Commission on Artificial Intelligence (NSCAI) – a high-profile commission of ex-government, industry, and academic experts led by Eric Schmidt – delivered its final report. The NSCAI explicitly recommended tightening export control “choke points” to keep China’s semiconductor industry at least two generations behind the United Stateswww.reuters.comwww.reuters.com. It urged Congress and the administration to coordinate with allies (Japan, Netherlands) on a “presumptive denial” policy for exporting advanced chipmaking tools to Chinawww.reuters.comwww.reuters.com. An NSCAI official bluntly told Reuters, “It boils down to semiconductors,” underscoring that leadership in chips underpins AI and thus future military and economic powerwww.reuters.com. These recommendations captured the shifting logic: beyond preventing military diversion of U.S. tech, the goal was to prevent China from ever catching up in the first place. The Biden Administration’s early actions reflected this mindset. In April 2021, BIS placed seven Chinese supercomputing entities (including national supercomputing centers and chip designers like Tianjin Phytium) on the Entity List, citing their role in supporting the Chinese military’s advanced weapons and AI developmentwww.csis.org. Notably, some were implicated in China’s efforts to simulate nuclear explosions and hypersonic weapons – tasks requiring powerful processors. The Commerce Department stated such HPC capabilities could facilitate “military-civil fusion” and even human rights abuses (e.g. mass surveillance)www.csis.org. By mid-2021, the White House had launched a 100-Day Supply Chain Review for critical sectors including semiconductors, which concluded that export controls should be updated to ensure U.S. leading-edge advantages are protectedwww.kwm.com. Throughout 2021, U.S. officials emphasized that allies and partners must work in tandem. Multilateral forums like the U.S.-EU Trade and Technology Council were established to align approaches on export screening and standardsbidenwhitehouse.archives.govbidenwhitehouse.archives.gov. “Small yard, high fence” became a catchphrase: focus controls on a small set of truly critical technologies, but guard them extremely tightly. In practice, however, defining the “yard” was contentious. Industry stakeholders urged clarity – for example, the Semiconductor Industry Association lobbied the government to narrowly define which “emerging technologies” would be controlled under ECRA so as not to stifle benign trade. Still, by 2021, a consensus was forming in Washington that advanced AI chips and chipmaking tools were squarely within that small yard of crucial tech to fence off from strategic rivals.2022 – Landmark Controls on Advanced AI Chips and Equipment: 2022 proved to be the watershed year in U.S. semiconductor export control policy. Early in the year, the Biden Administration prepared an unprecedented package of restrictions targeting China’s AI and supercomputing capabilities. National Security Advisor Jake Sullivan signaled the shift in a September 16 speech, declaring that the U.S. had to “revisit the longstanding premise” of export controls that sought only a “relative” advantagebidenwhitehouse.archives.gov. Whereas previous policy was satisfied to keep the U.S. “only a couple of generations ahead,” Sullivan argued this was no longer sufficientbidenwhitehouse.archives.gov. Given the “foundational” importance of technologies like advanced logic chips, “we must maintain as large of a lead as possible,” he statedbidenwhitehouse.archives.gov. This marked an explicit embrace of using export controls not just to deny immediate military end-use, but to broadly freeze China out of the cutting-edge. Sullivan cited how sweeping tech restrictions on Russia (after its Ukraine invasion) degraded Russia’s military – e.g. forcing them to use chips from dishwashers in tanks – as evidence that robust controls could “over time degrade [an adversary’s] battlefield capabilities”bidenwhitehouse.archives.gov. This philosophy set the stage for October 7, 2022, when the Commerce Department’s BIS rolled out a massive new set of rules on advanced computing exports to Chinawww.csis.org. These rules, published after some details had leaked in September, “upended decades of U.S. trade policy”www.csis.org by doing the following:

  • Advanced AI Chips: Restricting exports of high-performance AI processors (GPUs) above certain thresholds of computing power and interconnect speed to China without a licensewww.csis.orgwww.csis.org. This specifically hit Nvidia’s A100 and H100 GPUs and similar chips optimal for training large AI models. It was designed to “strangle the Chinese AI and supercomputing industries” by choking off access to high-end chipswww.csis.orgwww.csis.org. U.S. firms like Nvidia and AMD were now barred from selling their top AI chips to China, closing a key supply of “brain” hardware for machine learning.
  • Semiconductor Manufacturing Equipment (SME): Imposing a “presumption of denial” for licenses on export of the most advanced chip fabrication tools to Chinawww.csis.orgwww.csis.org. This covered equipment needed to produce logic chips at ~14 nm or smaller processes and DRAM at 18 nm or smaller, among others. The goal was to “block China from manufacturing advanced chips” domestically by denying it access to Western toolswww.csis.orgwww.csis.org.
  • EDA Software and Component Technologies: Controlling electronic design automation software for cutting-edge chip designs (like gate-all-around transistors) and certain semiconductor components. This was to “block China from designing AI chips domestically” by choking off critical design tools and high-end chip componentswww.csis.orgwww.csis.org.
  • U.S. Person Restrictions: For the first time, restricting U.S. persons from supporting Chinese chip development without a license. This meant American citizens or residents could not work on, or service, advanced fabrication in China. This novel measure sought to prevent American expertise from aiding China’s progress, addressing the “know-how” transfer.
  • Foreign Direct Product Rule Expansion: The new rules also expanded FDPR to cover foreign-made chips that meet the controlled specs – even if made offshore, they cannot be sold to China if U.S. technology was used in their productionwww.cnas.org. This closed loopholes by leveraging the ubiquity of U.S. chip tech. The October 7 regulations were sweeping in scope – “a massive policy shift” that ended the era of laissez-faire tech trade with Chinawww.csis.orgwww.csis.org. Notably, the rules intentionally erased the line between civilian and military uses for advanced chipswww.cnas.orgwww.cnas.org. In Sullivan’s words, for chips and supercomputing, maintaining a lead meant denying China these capabilities across the board, regardless of stated end-usewww.cnas.orgwww.cnas.org. The stated rationales in the official rule were couched in national security: to prevent China from obtaining advanced ICs for uses “contrary to U.S. national security and foreign policy interests”www.csis.orgwww.csis.org – which encompassed everything from military AI to surveillance regimes. But the strategic logic, as described by CSIS expert Gregory Allen, was broader: these actions were “not only to preserve chokepoint control but also [to] begin a new U.S. technology competition strategy”www.csis.orgwww.csis.org. In effect, the U.S. moved to “preserve its lead at all costs” in the race for AI-centric computing power.Impact and Reactions: The immediate impact in late 2022 was significant. Chinese tech companies scrambled – for instance, Alibaba and Tencent, which rely on GPUs for cloud AI services, had to halt certain upgrades. Prices for high-end graphics cards in China spiked overnight as consumers and firms hoarded what stock was leftwww.csis.orgwww.csis.org. U.S. firms, meanwhile, braced for a financial hit – Nvidia, for example, stood to lose an estimated $5.5 billion in potential revenue due to the inability to sell its flagship AI chips to Chinawww.reuters.comwww.reuters.com. (Nvidia quickly began developing China-specific lower-performance chips – like the A800 and H800 – that could pass the new thresholds, illustrating how industry tried to adapt within the

(Continued) Timeline of Key Policy Developments (2018–2023)

… The impact and reactions to the October 2022 rules were significant. Chinese tech giants like Alibaba and Tencent scrambled to secure alternative hardware, and prices for certain Nvidia graphics cards (sought for AI) surged among Chinese consumerwww.csis.org】. U.S. companies warned of lost sales – Nvidia alone estimated a potential $5.5 billion revenue impact from inability to sell its flagship AI chips to Chin】. In response, Nvidia and others began developing China-tailored chips that had capped performance to stay just within allowed limit】. These workarounds sought to mitigate commercial loss while technically complying. Critics in industry and some think tanks (like ITIF) argued such broad controls could inadvertently spur China’s indigenization and deprive U.S. firms of revenue needed for R&】. Proponents, however, believed cutting China off at the top end would slow its AI progress enough for the U.S. to extend its lead – a bet that was far from certain.2023 – Allied Coordination and “Small Yard, High Fence” in Practice: By early 2023, the U.S. had successfully brought key allies on board with its semiconductor restrictions, addressing a major potential loophole. In late January 2023, after months of diplomacy, *the Netherlands and Japan agreed (in principle) to align with U.S. export controls on advanced chipmaking equipmentwww.csis.orgwww.csis.org】. The Netherlands (home of ASML, the only maker of EUV lithography machines) and Japan (home to Nikon, Tokyo Electron, etc.) are crucial to deny China alternative sources. While details remained secret, it meant ASML’s cutting-edge EUV tools and Japan’s most advanced lithography and etching equipment would not be sold to China, thereby closing the biggest gap in the October rulewww.csis.org】. This allied coordination was framed as necessary because if the U.S. acted alone, others could fill the vacuum in China’s market – but now the “top three” suppliers were united, ensuring China couldn’t get the tech elsewherwww.csis.orgwww.csis.org】. U.S. officials touted this as vindication of the strategy: *“the gamble paid off”www.csis.org】. China’s reaction was furious yet constrained – it used economic coercion tools (like trade restrictions on Dutch and Japanese firms, and later in 2023 export curbs on critical minerals like gallium and germanium) to retaliat】. Still, Beijing couldn’t reverse the allied bloc’s decisions. In March 2023, China’s President Xi Jinping pointedly stated that the West’s containment efforts had made technological self-reliance a top priority, rallying domestic industry to “break through” the blockade.Domestically, October 2023 saw the Biden Administration update and tighten the export rules further. On October 17, 2023 (almost exactly a year after the initial rules), BIS issued updated regulations that “finalized and substantially tightened” the October 7 controlwww.csis.org】. These refinements closed technical loopholes (for instance, lowering the performance thresholds to catch China-specific chips like Nvidia’s A800 which had been designed to skirt 2022 rules). BIS also added more Chinese firms (like AI startup Biren Technology and others designing GPUs domestically) to the Entity List to ensure they couldn’t procure slightly lower-grade chips either. Furthermore, the U.S. clarified rules to cover **advanced chip substrates and other components being used to assemble high-end computing systems in China. By end of 2023, the U.S. made explicit that even AI chips used for cloud services accessible to China were under scrutiny, extending control to “cloud computing” exports (an emerging vector for China to access AI capability without importing chips directly). Commerce Department officials described China as attempting to *“divert a lot of civilian technologies… into supercomputers for civil-military fusion…and surveillance”】 – thus justifying the comprehensive tightening as directly aimed at this “far-reaching challenge】.Summary of Major U.S. Actions (2018–2023):
To synthesize this timeline, the following table summarizes key developments, actors, and stated rationales:

Date/PeriodAction/PolicyKey ActorsStated RationalesOutcomes/Notes
2018Export Control Reform Act (ECRA) enactedU.S. Congress (bipartisan)Identify & control “emerging and foundational” tech for national securit】; counter tech transfer to China’s militar】.Provided legal basis for new controls; launched process to define critical tech (AI, chips, etc.).
2019Huawei & affiliates on Entity List (May); initial AI chip license denialsTrump Admin; Dept. of Commerce (BIS)Nat’l security: Huawei posed espionage risk & aided PRC militar】. Prevent China’s misuse of AI/HPC for WMD or repression.Huawei cut off from U.S. chips (phone sales plunge); China’s 5G champion hobbled. China accelerates domestic chip design efforts as workaround.
2020Military End-Use (MEU) rule expansion (April); Foreign Direct Product Rule against Huawei (May/August)Trump Admin; BISNat’l security: Close loopholes where “civilian” trade aids PLA via MC】. Preserve U.S. lead by ensuring China stays 2 generations behind.SMIC & others targeted; Huawei’s access to TSMC chips blocked. Export control extraterritorial reach (FDPR) established a powerful preceden】.
2021NSCAI Final Report (Mar); new Entity List additions (supercomputing orgs); Supply Chain Review (Jun)NSCAI (Eric Schmidt); Biden Admin; BISTech leadership & nat’l security: “Boils down to semiconductors” – keep China two generations behin】. Limit AI chips for military/civil fusion uses.Recommendations for choke point controls on SME adopted in spirit. U.S. doubles down on “small yard, high fence” – few key techs (like EUV tools, AI chips) singled out.
Oct 7, 2022Landmark BIS rules on Advanced Computing & Semiconductor EquipmentBiden Admin; Nat’l Security Council; BISNat’l security & techno-competition: “Strangle” China’s AI and supercomputing by denying high-end GPU】. Maintain “as large a lead as possible” in chip】. Human rights: address chips used in surveillanc】.China’s AI firms lose access to best chips; U.S. firms lose China sales (Nvidia et al.). Marked start of U.S. tech containment strategy; partial decoupling in semiconductors begins.
Jan 2023U.S.-Japan-Netherlands deal on SME export controlsBiden Admin; Dutch & Japanese Govts.Nat’l security & allied unity: Present a united front so China can’t import from elsewhere; protect shared technological edgwww.csis.org】.ASML and Japanese toolmakers stop sales of top equipment to China. China protests, explores retaliations (e.g., rare earths, minerals).
Oct 2023BIS updates tightening rules (closing loopholes; more Entity List additions)Biden Admin; BISNat’l security (cont.): Prevent workaround via modified chips (e.g., Nvidia A800). Reiterate *MCF and human rights concerns】.Nvidia’s “China-custom” chips (A800/H800) now potentially in scope; further chill on China’s AI training capabilities.

This timeline underscores an evolution from targeted, case-by-case controls to a sweeping strategic approach. Initially, the focus was stopping direct military end-use (a narrower national security logic). Over time, justifications expanded to include maintaining a broad technology gap (techno-competition logic) and even an element of economic security (ensuring U.S. supply chain resilience and leverage, as emphasized in the CHIPS Act and Sullivan’s doctrine).

Shifting Rationales: National Security vs. Economic vs. Technological Competition

One of the core dynamics in this history is how the rationales for export controls have been framed and re-framed by various actors. Below, we categorize and trace these logics:

National Security Logics

Military Applications and Dual-Use Concerns: From the start, national security has been the foremost justification. Advanced semiconductors are dual-use – they power both consumer devices and military systems. U.S. officials repeatedly voiced concerns that China could use high-end American chips in weapons, surveillance, or to enhance its military AI capabilities (like autonomous drones or cyber warfare). The expansion of China’s military-civil fusion erased clear distinctions, so the U.S. began treating even ostensibly civilian tech exports as potential military enablers】. For example, Gina Raimondo (Commerce Secretary) often cited China’s blurring of civilian/military R&D as a reason for all-encompassing chip controls. By 2023, a Commerce official noted China tries to “divert a lot of civilian technologies… into supercomputers in civil-military fusion programs”, including for **“surveillance that link with human rights abuses”】. This frames export controls as not just protecting U.S. military advantage, but also preventing U.S. tech from enabling oppressive practices (tying into values-based arguments about not abetting genocide or authoritarian surveillance). The national security rationale has thus broadened: it started with concerns like (1) nuclear weapons research & missile technology (e.g., why supercomputing chips were barred), (2) military command, control, communications & intelligence (C4ISR) (need to deny China chips that could give an AI edge in conflict), and (3) human rights (preventing chips from powering China’s AI surveillance state in Xinjiang and beyond).“Chokepoint” Strategy to Degrade Adversary Capabilities: Influential voices like the NSCAI and officials like Sullivan added another layer: use export controls proactively to slow an adversary’s overall tech advancement. Sullivan explicitly said robust controls can *“impose costs on adversaries, and even over time degrade their battlefield capabilities”】. The Russia example (2022) – where controls forced Russia to scavenge for chips – became a proof-of-concept that informed the China approac】. Thus, by late 2022, the national security logic was not just defensive (protect U.S. tech), but offensive – to hamstring China’s future military potential by cutting off inputs. This is essentially a long-term denial strategy: e.g., deny PLA developers access to AI model training chips now, so that in 5–10 years the PLA’s AI systems are generations behind. The U.S. DoD and National Security Council have supported this line, often couched as buying time in the military competition with China.

Economic Competitiveness and Supply Chain Resilience

Maintaining a Technological Lead = Economic Strength: While couched in security terms, many justifications also emphasize the economy. Cutting-edge chip tech is seen as the engine of future industries (AI, quantum, advanced manufacturing). “Leadership in these is a national security imperative,” Sullivan note】. Policymakers argue that whoever leads in AI and semiconductors will reap outsized economic gains and standard-setting power. Thus, export controls are partly about preserving U.S. economic competitiveness by slowing a rival’s rise. This is a shift from older thinking – previously, economic logic argued against controls (free trade maximizes innovation and market share). Now, the logic is that certain tech is so critical that allowing China to catch up would ultimately undermine U.S. economic dominance. The CHIPS and Science Act of 2022 which poured $52B into domestic chip manufacturing, was one side of this coin (a positive industrial policy), while export controls were the other (a defensive measure】. Both were promoted as necessary for U.S. economic security.“Supply Chain Security” and Overreliance Concerns: The 2021–2022 supply chain disruptions (pandemic-driven chip shortages) also factored in. It alarmed U.S. policymakers that so much chip production was in Asia (Taiwan, South Korea) and that the U.S. was dependent on potential adversaries for key materials. The White House 100-Day Supply Chain Review (June 2021) highlighted this and suggested *export controls should ensure the U.S. isn’t fueling China’s advance at the expense of its own resilience】. In Sullivan’s 2022 speech, he referenced how the pandemic exposed “alarming” supply chain vulnerabilities and that “there is no way back” to the old ecosyste】. The implication: economic decoupling in chips is partly to ensure the U.S. and allies control their own destinies in this foundational tech. Indeed, by 2023, U.S. officials openly spoke of re-architecting supply chains to be oriented around the U.S. and trusted partners (friend-shoring), implicitly accepting some decoupling from China.Industry and Innovation Base Considerations: There’s a paradox in the economic logic. U.S. industry initially feared losing the huge China market, which could reduce their revenues and thus R&D budgets (potentially undermining U.S. technological leadership long-term). For example, a 2023 CSIS report noted U.S. firms lost market share and that *“over time, this loss… could undermine the competitiveness of U.S. firms”】. The Semiconductor Industry Association (SIA) and major firms lobbied for narrow controls, warning that broad ones might “chip away at American [industry] leadership”. However, over time, the U.S. government argument evolved to say short-term revenue losses are an acceptable trade-off for long-term security and tech dominance. The CHIPS Act subsidies were, in part, meant to offset these losses by boosting domestic demand. Meanwhile, officials like Commerce’s Alan Estevez suggested the U.S. must be comfortable with its firms possibly losing some China sales if it means China’s military doesn’t get the tech. By late 2023, a broad consensus in Washington (though not necessarily in Silicon Valley) held that maintaining the West’s edge in semiconductors justifies some economic sacrifice, aligning economic and security rationales.

Technological Competition and AI Scaling Concerns

AI Compute and Scaling Laws: A unique aspect of recent export controls is their focus on computing power for AI – essentially trying to govern the trajectory of AI development in China by throttling “access to compute.” This reflects growing awareness of machine learning scaling laws: the more powerful chips and larger datasets you have, the more advanced AI models you can train. Frontier AI development (like large language models and next-gen AI for military use) requires enormous computational resources, usually delivered by state-of-the-art GPUs or AI accelerators. U.S. policymakers, informed by think tanks like CSET and others, recognized that advanced GPUs (like Nvidia A100/H100) are crucial strategic assets because they enable training of cutting-edge AI models (from autonomous drone swarms to AI surveillance analytics). Thus, the 2022 export controls explicitly targeted general-purpose GPUs optimized for AI – a novel focus. CSET’s analyses in 2022–2024 often discussed how limiting China’s access to “AI compute” could slow its progress in large model A】. At the same time, CSET warned that if the controls were too broad (e.g., inadvertently covering CPUs that have AI feature】), it could push China to double down on domestic innovation or adopt alternative chip architectures.“Small Yard, High Fence” vs. “Growing Yard”: Initially, officials described the controls as covering a small number of most-critical items (like top-tier chips and tools) – the small yard. But technology evolves quickly, and by 2023, it was clear the yard had to expand (e.g., lowering thresholds, adding CPUs with AI accelerators to the lis】). CSET called this the “growing yard” phenomenon – as AI technology diffuses into more products, the controls catch more items than first intende】. For instance, advanced CPUs started integrating AI cores, and suddenly even Intel or AMD general processors could breach control limits. Policymakers had to decide whether to carve those out or not, balancing the competition logic (don’t give China any edge) against practical industry impact. Over time, the logic of staying “as far ahead as possible” technologically has mostly won out, resulting in expanding controls. There is an implicit recognition that AI is a game-changer – if China were to surpass the U.S. in AI capabilities due to unfettered access to compute, it could translate to both economic and military dominance in the future. This specter drives the techno-competition rationale strongly.Academic and Think Tank Perspectives: Many scholars and think-tank experts supported the goal of maintaining U.S. lead but debated the means. Some at CSIS, CNAS, and Brookings backed strict controls but urged coupling them with domestic R&D investment (since *“export restrictions alone cannot substitute for comprehensive industrial policy”】). Others warned of diminishing returns: if China is determined and capable, it will eventually find alternatives or innovate around controls (e.g., using chiplet architectures, open-source designs, etc.). A CNAS commentary by Paul Scharre (Jan 2023) argued that denying chips now might accelerate China’s drive for self-sufficiency and that a better long-term strategy is keeping China dependent so the U.S. can withhold tech as leverage in a crisi】. This was a minority view in policy circles; the prevailing view became that once China was near-peer, dependence-as-leverage was too risky, and it was better to cut them off preemptively. The debate illustrated a tension between short-term vs. long-term thinking in technological competition.

Human Rights and Ethical Considerations

While not as central as security/economic reasons, the U.S. government increasingly folded ethical arguments into export control justifications. The use of American technology (like Intel and Nvidia chips) in China’s mass surveillance of Uyghurs and other minorities was widely reported in late 2010s. Congress and human rights groups pushed for action. In 2019, several Chinese AI surveillance firms (e.g., Hikvision, SenseTime, Megvii) were added to the Entity List for human rights reasons. These moves signaled that export controls were also a tool to address values – ensuring U.S. technology isn’t complicit in atrocities. The October 2022 rules mentioned preventing chips for “surveillance and repression” as part of foreign policy interests. By framing it thus, the administration could rally broader support (it’s harder to object to a policy aimed at not abetting human rights abuses). However, cynics might note this rationale often aligned with strategic interest – i.e., the same chips that power surveillance also power military AI. Nonetheless, it’s a notable part of the narrative: the U.S. is positioning its tech policy as upholding a liberal order against authoritarian misuse of tech.

Achievements vs. Original Goals: Has the U.S. Strategy Worked?

After several years of escalating controls, it’s important to evaluate: To what extent has the U.S. achieved its initial goals, and have those goals shifted?Original Goals (implicit and explicit): Early on (2018–2019), the goals were narrower: (1) Protect U.S. national security by denying China tech that would directly bolster its military or surveillance state. (2) Induce China to play fair on tech (e.g., reduce IP theft, abide by rules) by demonstrating U.S. willingness to withhold key tech. (3) Maintain a relative edge (2-generation lead) in key dual-use technologies. By 2022, the goals expanded to: (4) Freeze China’s progress in AI and advanced computing where possible (i.e., slow them down enough that the U.S. can extend its lead). (5) Safeguard U.S. supply chain security and reduce critical dependencies on China. (6) Coordinate an allied tech denial regime to present a united front.Achievements:

  • Slowing Chinese Military AI/Advanced Computing: The U.S. has undoubtedly impaired China’s near-term capabilities in certain areas. For instance, China’s leading AI firms like SenseTime and Baidu can no longer readily obtain top GPUs, which has reportedly forced them to use larger clusters of older chips – less efficient for training large AI models. Chinese supercomputers that might be used for nuclear simulation or hypersonics R&D face delays or performance limitations without access to U.S. accelerators. As one metric, China’s placement in the TOP500 (a ranking of supercomputers) saw fewer new entrants after 2020, possibly due to difficulty obtaining parts. Chinese military programs that rely on high-end chips (from satellite imagery analysis to advanced radar) likely have had to make do with less optimal hardware, which could slow development. So in the short run, goal (1) – slowing military AI progress – has been partly met. However, China is adapting; e.g., Huawei’s 2023 release of a 7nm smartphone chip made domesticallywww.csis.org】shows it is finding ways to innovate under sanctions, albeit at higher cost and slower pace.
  • Maintaining/Extending Tech Lead: The U.S. still leads in cutting-edge chip design (Nvidia, AMD) and semiconductor manufacturing equipment (Applied Materials, Lam, KLA). By denying China access, the U.S. and its close allies (Taiwan’s TSMC, South Korea’s Samsung) continue to operate roughly 2+ generations ahead of China’s best. China’s most advanced logic chip production is stuck at ~7nm (with heavy yield issues), whereas TSMC/Intel/Samsung are moving to 3nm and below. This suggests the goal of keeping China a couple generations behind is being achieved so far. Moreover, the U.S. “big three” EDA software firms (Cadence, Synopsys, Mentor) withdrew support from Chinese customers, making it harder for China to design at the leading edge. An important caveat: these achievements are holding actions. China is investing heavily in catching up, and some experts caution that export controls only buy time unless the U.S. also runs faster (invests in its own innovation). The U.S. has ramped up R&D funding via the CHIPS Act and related initiatives, which can be seen as part of achieving the spirit of the goal (extend lead via both denying adversary and boosting oneself).
  • Allied Coordination: Initially, a big risk was that unilateral U.S. controls would fail if allies didn’t cooperate. By securing deals with the Netherlands, Japan (and effectively South Korea and Taiwan’s informal compliance), the U.S. built a coalition controlling the choke points. This is a significant diplomatic achievement. The trilaterial agreement (U.S.-NL-Japan) in early 2023 was critical in blocking China’s lithography access. There is still work to fully align (the deal wasn’t public or formal, and each country implemented it slightly differently), but goal (6) – allied coordination – is on track. European Union-wide controls are slower (due to consensus issue】), but key member states are acting. The U.S. also managed to get Taiwan to enforce the Foreign Direct Product rule, plugging a huge ga】. Without ally support, Chinese firms could have backfilled via Dutch/Japanese suppliers; that door is largely closed. So, in that sense, the U.S. achieved a major original goal by mid-2023.
  • Chinese Tech Behavior: If one goal was to pressure China to curb IP theft and unfair practices, the results are less clear. China did pass new IP laws and eased joint-venture pressure in 2020-21 (partly due to the Phase One trade deal), but it hasn’t fundamentally altered its strategic course (Made in China 2025 ambitions quietly continue). Export controls arguably hardened China’s resolve to pursue self-reliance more aggressively rather than making it more accommodating. There is little evidence that China has become a more responsible tech player due to these measures – instead, tech has become even more politicized in the rivalry.
  • U.S. Supply Chain Resilience: By making Chinese components and equipment off-limits, U.S. and allied firms have had to diversify their supply chains. The CHIPS Act investments will yield new fabs in the U.S. (though not at leading edge initially, mostly 5-10nm processes). Goal (5) of reducing dependency on China is gradually progressing: e.g., TSMC and Samsung are building fabs in Arizona and Texas, respectively, which in a few years will lessen reliance on Asian production. However, this is a medium-term outcome. In the short term, U.S. industry had to adjust to lost Chinese inputs for certain low-end chips or materials. Interestingly, China’s 2023 retaliation (restricting exports of gallium and germanium – key for chipmaking) showed that the U.S. still depends on China for some upstream inputs, an area that needs work. Redefinition or Continuation of Goals: Current arguments for maintaining or expanding controls seem to be a continuation of the later goals with some refinement:
  • From Maintaining a Lead to Maximum Isolation: Initially, the phrasing was “a couple generations ahead” (relative lead). Sullivan’s doctrine changed that to “as large a lead as possible】. That suggests the goalposts moved – now it’s not enough that China is behind; it should remain indefinitely behind in critical domains. This is effectively a redefinition from maintain an edge to actively ensure China cannot catch up. The October 2022 rules were the inflection of that new goal.
  • Economic Security as Security: Whereas earlier arguments balanced economic interests, now officials equate economic competitiveness with national security. The term “techno-security” strategy is apt – ensuring America’s technological base (which underpins economic strength) is secure from being hollowed out by China. So, the goal has been broadened: not only deny China, but also rebuild domestically. In speeches, Biden officials often mention export controls in the same breath as the CHIPS Act, implying the real goal is a healthier U.S. tech ecosystem that doesn’t feed a rival’s rise. Thus, maintaining controls now is sold as essential for American innovation leadership, not just a defensive move.
  • AI Governance and Global Norms: Another emerging rationale (post-2023) is the idea that the U.S., by controlling AI tech diffusion, is trying to set global rules for AI. The Carnegie Endowment has written about the U.S. attempt to “govern AI’s global spread” via export control】. In other words, if AI is the transformative tech of our era, whoever controls the top AI compute can influence how and where AI is developed responsibly. This is a more nuanced, strategic rationale – blending traditional security with a form of technological statesmanship. It’s somewhat new and can be seen as a redefinition of goals: from just slowing China to also shaping the trajectory of AI worldwide (with an implicit stance that authoritarian AI development should be constrained). Unintended Effects and Challenges: It is also worth noting areas where goals have not been fully met or new challenges have arisen:
  • Chinese Acceleration and “Malign Competitiveness”: Far from giving up, China responded to controls with massive state investment in semiconductors. By 2023, China’s government set up multi-billion dollar funds (the “Big Fund” II, etc.), and local firms made breakthroughs like YMTC’s 3D NAND memory chips and Biren’s domestic AI chips (though Biren was added to the Entity List to stymie them). Some experts fear that export controls could spurr “leapfrogging” – China might find novel approaches that bypass Western tech, which could surprise the U.S. For example, if China achieves a breakthrough in chip architecture or quantum computing, the whole paradigm of control might shift. This was pointed out by CSIS: *“doubling down on deeply subsidized development efforts… could produce breakthrough technologies… potentially destabilizing the U.S. semiconductor ecosystem”】. So while goals are met in short term, the long-term is an open question.
  • Gaps and Enforcement Issues: The U.S. found that enforcing such broad controls globally is hard. There have been reports of smuggling and diversion – e.g., chips shipped to subsidiaries in third countries then rerouted to Chin】. Chinese traders turned to the gray market. Policing this requires significant resources and international cooperation. The U.S. has ramped up enforcement (the Justice Department’s “China Initiative” initially, now a broader effort targeting export evasion), but ensuring compliance in places like Southeast Asia is challenging. Thus, achieving the goal of comprehensively denying China is tough – some leakage occurs. The current argument to maintain controls acknowledges these gaps but posits that tightening loopholes and aligned ally rules (e.g., closing the UAE re-export hub) can mitigate it.
  • Impact on U.S. Firms and Innovation: As anticipated, U.S. companies did take a hit. The longer-term effect on their R&D is not yet fully known. Some argue that loss of the China market could reduce U.S. chip firms’ ability to invest in future technology, ironically harming the goal of maintaining a lead. The Biden Administration has tried to address this via subsidies and by expanding markets elsewhere (encouraging sales to India, for instance). If over the next few years U.S. firms still lead in revenues and innovation, then the strategy will be validated. But if they slip while China’s subsidized competitors catch up in older tech (and then maybe in new tech), the U.S. might have to reassess the balance of controls vs. competitiveness. Continuity vs. Redefinition: So far, the arguments for maintaining or expanding controls (as of 2024-2025) seem to be a continuation of the approach begun in 2022, rather than a complete redefinition. They emphasize that the job isn’t finished: China still aspires to lead in AI and chips by 2030s, so the restrictions must stay or even tighten until China’s ambitions are “managed.” Some shifts in tone include more open talk of tech containment (though officials avoid that term publicly, preferring “protecting our advantages”). If anything, the framing has shifted from a defensive crouch (circa 2018: “we need to stop helping China’s military”) to a more assertive stance (circa 2024: “we will do whatever it takes to ensure China remains behind us in tech”). This is a continuum, not a U-turn.

Coordination with Allies: A Multilateral Web of Controls

As noted, ally coordination is a linchpin of success. After the 2023 alignment with the Netherlands and Japan, focus turned to integrating more allies:

  • Taiwan and South Korea: These are home to TSMC, Samsung, SK Hynix – essential chip producers. They have mostly complied with U.S. rules (e.g., SK Hynix and Samsung were given waivers to continue operating fabs in China at certain technology levels, but agreed not to advance them). Taiwan publicly supported the FDPR applicatio】. Their cooperation has been driven by a mix of U.S. pressure and their own self-interest in constraining a potential Chinese competitor. However, both are wary – they want to continue selling older-gen chips to China (a huge market for those), so the U.S. has had to calibrate allowances.
  • Europe (EU): The EU as a bloc hasn’t fully matched U.S. controls, partly due to internal division. The Netherlands was key (with ASML), and once it acted, Europe’s leverage decreased. The EU is considering new legal authority to do export controls collectivel】, but that’s slow. Meanwhile, countries like Germany have significant trade with China and are cautious. Still, Europe’s biggest tech players (like ASML, Nokia/Ericsson in 5G, etc.) are on guard and often follow U.S. export guidance informally. The U.S.-EU Trade and Tech Council facilitates some of this discussion. The U.K. and Canada have mirrored some U.S. moves too (e.g., blocking Chinese investment in chip firms).
  • Japan: In 2023, Japan announced its own set of export restrictions on 23 types of chip-making technology, which align closely with U.S. goal】. Unlike the U.S., Japan’s approach doesn’t single out China by name – it’s couched generally, but everyone knows the intent. Japanese industry had concerns (China is a top market), but Tokyo balanced this with the recognition that Japan’s security is directly tied to U.S. tech leadership in any conflict scenario. Ally Challenges: Despite progress, differences remain. As CSIS noted, allies often have narrower controls and do not want to apply extraterritorial rules like the U.S】. For instance, a Japanese firm could in theory ship from a subsidiary outside Japan to skirt domestic controls, though doing so risks U.S. retaliation or loss of U.S. partnership. The U.S. also had to address South Korea’s concerns: SK Hynix and Samsung have huge fabs in China and billions at stake. The U.S. gave them time-limited waivers to continue operations. By 2025, those waivers need extension or adjustment, a delicate point in ally coordination.Global Semiconductor Order Reshaped: The collective result of these allied efforts is that China is now largely isolated from the cutting edge of the global semiconductor supply chain. It can still import older-generation tech freely (for now), which is why Chinese companies are turning to mature nodes (28nm, 40nm) – good enough for many applications but not high-end AI. The goal for allies is to hold that line and push it forward as tech advances (i.e., today 14nm is cutoff, tomorrow it might be 28nm as the world moves to 2nm). This is a moving target.

Conclusion: The New Status Quo and Future Outlook

What began as targeted export restrictions has evolved into a broad strategic doctrine: the U.S. and its allies are actively preventing China from obtaining the most advanced semiconductors, not just for immediate security reasons, but to shape the long-term balance of power in technology. The justifications have intertwined national security with economic and technological competition rationales, making export controls a central tool of Great Power competition policy.Continuation of Original Goals: The core original goals – protect U.S. security, maintain a tech lead – remain, but they have been amplified. The U.S. has largely met near-term aims (Chinese advanced tech progress slowed, U.S. lead sustained), but faces the task of sustaining this over years. Current arguments for keeping or even widening controls emphasize:

  • The job is not done – China is investing massively to overcome these barriers, so relaxing now would squander the progress.
  • The threat environment has, if anything, worsened – e.g., China’s military advances like hypersonic tests (2021) and aggressive moves mean tech denial is as critical as ever.
  • Controls are part of a broader strategy including domestic revival (CHIPS Act) and ally networks (Chip 4 alliance with Taiwan, Japan, Korea). Removing one leg (controls) would undermine the whole.
  • Ethically, it remains imperative to ensure U.S. tech isn’t fueling potential adversary militaries or human rights abuses. Redefinition of Goals: Subtly, some goals have indeed been redefined: rather than just slowing Chinese military AI, some officials hint at ensuring the U.S. decisively outpaces China in AI. Instead of just maintaining a lead, it’s now ensuring China cannot threaten that lead in critical domains. These are shifts in degree, reflecting confidence that the U.S. can and should use its leverage to the maximum extent.Effectiveness and Long-Term Risks: The U.S. strategy’s effectiveness long-term is debated. If judged up to 2023, it successfully imposed significant costs on China’s tech secto】 – causing short-term disruption, and compelling China to pour resources into catching up. Some fear this might actually galvanize China’s tech self-sufficiency (the “Sputnik” effect for China), eventually eroding U.S. advantages if China manages to innovate around U.S. inputs. Others believe China’s dependence on Western tech was a vulnerability that had to be exploited eventually, and doing so now while the U.S. holds clear advantages is wise – even if it accelerates China’s efforts, starting from behind is hard due to the complexity of semiconductor ecosystems. The truth may be mixed: we might see China achieve partial success in some areas (like memory chips or older node logic) but struggle in others (EUV lithography, cutting-edge GPUs) for a prolonged period. Meanwhile, U.S. controls will have to continuously adapt to technology changes (e.g., new AI paradigms beyond GPUs, potential developments in chiplet architectures or optical computing that might circumvent current definitions).Concluding Note: The semiconductor export controls against China from 2018 to present represent a landmark in the intellectual history of tech policy – a shift from post-Cold War laissez-faire globalization toward technological containment and strategic decoupling in certain key sectors. They blur the lines between economic policy and national security policy. Think tanks have variously lauded this as necessary and overdue, or cautioned against overreach that could undermine U.S. innovatio】. The White House and Commerce Department maintain that this course is a *“grand vision” over five or six years】 to secure the free world’s technological edge. As of 2025, the new status quo is one of persistent tension: the U.S. leveraging its semiconductor chokehold to constrain China, and China undertaking a whole-of-nation effort to break that chokehold. The coming years will reveal whether this strategy results in a stable advantage for the U.S. (a continued “silicon separation” favoring the West), or whether it triggers a technology sprint that eventually diminishes U.S. influence in global semiconductor standards and markets.Either way, the export controls have fundamentally redefined U.S.-China relations in technology. The era of relatively unfettered exchange is over; we are in an era where strategic competition in AI and chips shapes trade rules. The intellectual justification for this – balancing national security with economic-technological competition – will likely influence other domains, from quantum computing to biotechnology, as the U.S. applies the lessons learned in the semiconductor “small yard, high fence” saga.

Intellectual History of U.S.-Led Semiconductor Export Controls Targeting China (2018–Present)

President Biden holding a semiconductor chip while discussing supply chain security in early 2021. U.S. policymakers have increasingly viewed advanced chips as critical strategic assets, linking them to national security and economic competitiveness.

Introduction

The United States has progressively tightened export controls on semiconductors and related technology to China, especially from 2018 to the present. This report traces the evolution of these controls, including earlier foundations, and examines the shifting justifications offered by U.S. government agencies, think tanks, academics, and industry stakeholders. What began as targeted measures aimed at specific national security risks has broadened into a comprehensive strategy to maintain U.S. technological superiority in advanced computing and artificial intelligence (AI). Key rationales – spanning national security, economic competitiveness, and technological leadership – have been emphasized to varying degrees over time. We present a timeline of major policy developments, highlight the arguments and proposals from influential voices, and assess whether the U.S. has achieved its initial goals (such as slowing China’s military AI progress and preserving a technology lead) or redefined those goals as circumstances changed. Clear headings, a timeline of events, and summary tables are provided for ease of reference.

Background: Foundations of Export Controls and China’s Tech Ambitions (Pre-2018)

U.S. export controls on advanced technology are not new – they have Cold War origins and were retooled after the Tiananmen Square sanctions of 1989 to bar arms sales to Chinasgp.fas.org. By the 1990s and 2000s, however, many dual-use technology exports to China were liberalized in line with globalization and U.S. business interestssgp.fas.orgsgp.fas.org. This enabled China to import vast amounts of U.S. high-tech components with minimal restrictions. Meanwhile, China undertook state-led initiatives to reduce dependence on foreign technology and achieve leadership in strategic sectors. Notably, the Made in China 2025 industrial plan (launched in 2015) set ambitious targets to dominate industries like semiconductors, AI, aerospace, and robotics, often by leveraging foreign technologysgp.fas.org. In parallel, China’s Military-Civil Fusion (MCF) policy sought to ensure that advancements in “civilian” high-tech (often acquired from abroad) directly supported the Chinese militarysgp.fas.org. U.S. officials and experts grew concerned that China’s approach was blurring the line between civilian and military end-uses, complicating traditional export control distinctionssgp.fas.org. By the late 2010s, it was evident that China’s rapid progress in supercomputing, AI, and telecommunications (sometimes aided by illicit acquisition of U.S. know-howbidenwhitehouse.archives.gov) could eventually threaten U.S. technological and military advantages. This context set the stage for a significant tightening of U.S. export control policy toward China.

Timeline of Key Policy Developments (2018–2023)

2018 – Turning Point: The U.S. government began overhauling its export control framework in response to China’s tech rise. In August 2018, Congress passed the Export Control Reform Act (ECRA) as part of the National Defense Authorization Act. ECRA reestablished the President’s broad authority to control “emerging and foundational technologies” for national security, and mandated identifying critical cutting-edge tech (like advanced semiconductors and AI) that should be regulatedsgp.fas.orgsgp.fas.org. This legislative change reflected bipartisan alarm that Beijing’s drive for tech leadership (and reports of intellectual property theft) could erode U.S. security and economic primacy. Also in 2018, the impact of export controls became starkly clear when the Commerce Department’s Bureau of Industry and Security (BIS) imposed a denial order on Chinese telecom firm ZTE, cutting off its access to U.S. chips. ZTE’s operations nearly collapsed, underscoring U.S. leverage over Chinese tech firms dependent on American components. Although the ZTE ban was later lifted after fines and agreements, it foreshadowed the coming “tech decoupling.” Around the same time, U.S. authorities brought charges against Chinese state-backed chip company Fujian Jinhua for stealing memory chip designs, and moved to block its access to U.S. technologywww.reuters.comwww.reuters.com. These actions sent an early signal that advanced semiconductor know-how was now viewed through a national security lens.2019 – Entity List Expansion and Initial AI Chip Restrictions: In 2019, the Trump Administration steadily expanded the use of the Entity List, a tool to restrict specific foreign companies from receiving U.S. exports without a licensesgp.fas.org. In May 2019, Chinese telecom giant Huawei and dozens of its affiliates were added to the Entity List, citing national security concerns (Huawei was accused of facilitating espionage and had close ties to the state). This move “effectively cut off Huawei’s access to key U.S. semiconductors” and other inputswww.csis.orgwww.csis.org. U.S. chipmakers could no longer supply Huawei freely, disrupting Huawei’s smartphone business and its ability to source advanced chips for 5G network gear. The official rationale focused on telecommunications security and potential military uses, but it also carried economic overtones (preventing China from overtaking in 5G). Beijing decried the blacklisting as unjustified, while U.S. think tanks like CSIS noted it reflected a “growing policy consensus” on the need to get tough on Chinese tech firmswww.csis.org. Separately, in late 2019, the Commerce Department began denying licenses for certain AI-related chip exports to China. For example, U.S. firms were barred from selling leading-edge GPU accelerator chips to specific Chinese supercomputing centers implicated in nuclear weapons research or surveillance. These early curbs were relatively narrow, targeting clearly military-linked end users (e.g. China’s National Supercomputing centers and companies like Sugon) to “deny China direct and significant military benefits” from U.S. techsgp.fas.org. Still, they signaled a broader concern that advanced AI chips and high-performance computing (HPC) could enhance China’s military AI development or repression apparatus (e.g. AI-driven surveillance of minority populations).2020 – Tightening the Noose (Military End-Use Rules and Foreign Direct Product Rule): By 2020, U.S. export control policy explicitly linked advanced semiconductors to national security in new ways. In April 2020, the Commerce Department eliminated civil-use license exceptions for exports to China, Russia, and Venezuela, expanding the scope of items requiring licenses when destined for military end-users in Chinawww.piie.com. This Military End-Use rule expansion meant even relatively common electronics could be restricted if going to a company with any tie to China’s military, reflecting the reality of MCF. Then in May and August 2020, the U.S. dramatically expanded the Foreign Direct Product Rule (FDPR) to further choke off Huawei’s access to semiconductors. Under the FDPR extension, foreign-made chips that were produced using U.S. software or equipment (ubiquitous in chip fabrication) were now subject to U.S. licensing if aimed at Huaweiwww.cnas.org. In essence, Washington applied its controls extraterritorially, leveraging U.S. dominance in chip design tools and manufacturing gear to block Huawei from getting advanced chips made by third parties like TSMC in Taiwanwww.cnas.org. This was a novel use of U.S. regulatory power; it illustrated what some analysts termed “weaponizing interdependence” – akin to how the U.S. uses its financial clout via the dollar, but now applied to tech supply chainswww.cnas.orgwww.cnas.org. While aimed at a single company, this set a precedent for broader semiconductor controls. Industry stakeholders grew uneasy as China was a major market – U.S. semiconductor exports to China hit record levels in 2020 even amid the trade warwww.congress.gov. Nonetheless, national security officials justified the measures as necessary to prevent cutting-edge U.S. chips from advancing China’s military communications and AI-enabled surveillance state. In the short term, Huawei’s ability to produce advanced smartphones and 5G base stations was indeed crippled, one of the first clear outcomes of the export control offensive. In another notable 2020 action, SMIC (Semiconductor Manufacturing International Corp) – China’s leading chip fab – was added to the Entity List in December, on the grounds that its chips might go to Chinese military systems. These steps reflected a widening view that entire segments of China’s semiconductor sector (design, fabrication, and supercomputing) were intertwined with security concerns.2021 – A New Administration and Strategic Reviews: The Biden Administration took office in January 2021 and largely continued the tough line on tech exports to China, while conducting reviews to formulate a unified strategy. In March 2021, the congressionally-mandated National Security Commission on Artificial Intelligence (NSCAI) – a high-profile commission of ex-government, industry, and academic experts led by Eric Schmidt – delivered its final report. The NSCAI explicitly recommended tightening export control “choke points” to keep China’s semiconductor industry at least two generations behind the United Stateswww.reuters.comwww.reuters.com. It urged Congress and the administration to coordinate with allies (Japan, Netherlands) on a “presumptive denial” policy for exporting advanced chipmaking tools to Chinawww.reuters.comwww.reuters.com. An NSCAI official bluntly told Reuters, “It boils down to semiconductors,” underscoring that leadership in chips underpins AI and thus future military and economic powerwww.reuters.com. These recommendations captured the shifting logic: beyond preventing military diversion of U.S. tech, the goal was to prevent China from ever catching up in the first place. The Biden Administration’s early actions reflected this mindset. In April 2021, BIS placed seven Chinese supercomputing entities (including national supercomputing centers and chip designers like Tianjin Phytium) on the Entity List, citing their role in supporting the Chinese military’s advanced weapons and AI developmentwww.csis.org. Notably, some were implicated in China’s efforts to simulate nuclear explosions and hypersonic weapons – tasks requiring powerful processors. The Commerce Department stated such HPC capabilities could facilitate “military-civil fusion” and even human rights abuses (e.g. mass surveillance)www.csis.org. By mid-2021, the White House had launched a 100-Day Supply Chain Review for critical sectors including semiconductors, which concluded that export controls should be updated to ensure U.S. leading-edge advantages are protectedwww.kwm.com. Throughout 2021, U.S. officials emphasized that allies and partners must work in tandem. Multilateral forums like the U.S.-EU Trade and Technology Council were established to align approaches on export screening and standardsbidenwhitehouse.archives.govbidenwhitehouse.archives.gov. “Small yard, high fence” became a catchphrase: focus controls on a small set of truly critical technologies, but guard them extremely tightly. In practice, however, defining the “yard” was contentious. Industry stakeholders urged clarity – for example, the Semiconductor Industry Association lobbied the government to narrowly define which “emerging technologies” would be controlled under ECRA so as not to stifle benign trade. Still, by 2021, a consensus was forming in Washington that advanced AI chips and chipmaking tools were squarely within that small yard of crucial tech to fence off from strategic rivals.2022 – Landmark Controls on Advanced AI Chips and Equipment: 2022 proved to be the watershed year in U.S. semiconductor export control policy. Early in the year, the Biden Administration prepared an unprecedented package of restrictions targeting China’s AI and supercomputing capabilities. National Security Advisor Jake Sullivan signaled the shift in a September 16 speech, declaring that the U.S. had to “revisit the longstanding premise” of export controls that sought only a “relative” advantagebidenwhitehouse.archives.gov. Whereas previous policy was satisfied to keep the U.S. “only a couple of generations ahead,” Sullivan argued this was no longer sufficientbidenwhitehouse.archives.gov. Given the “foundational” importance of technologies like advanced logic chips, “we must maintain as large of a lead as possible,” he statedbidenwhitehouse.archives.gov. This marked an explicit embrace of using export controls not just to deny immediate military end-use, but to broadly freeze China out of the cutting-edge. Sullivan cited how sweeping tech restrictions on Russia (after its Ukraine invasion) degraded Russia’s military – e.g. forcing them to use chips from dishwashers in tanks – as evidence that robust controls could “over time degrade [an adversary’s] battlefield capabilities”bidenwhitehouse.archives.gov. This philosophy set the stage for October 7, 2022, when the Commerce Department’s BIS rolled out a massive new set of rules on advanced computing exports to Chinawww.csis.org. These rules, published after some details had leaked in September, “upended decades of U.S. trade policy”www.csis.org by doing the following:

  • Advanced AI Chips: Restricting exports of high-performance AI processors (GPUs) above certain thresholds of computing power and interconnect speed to China without a licensewww.csis.orgwww.csis.org. This specifically hit Nvidia’s A100 and H100 GPUs and similar chips optimal for training large AI models. It was designed to “strangle the Chinese AI and supercomputing industries” by choking off access to high-end chipswww.csis.orgwww.csis.org. U.S. firms like Nvidia and AMD were now barred from selling their top AI chips to China, closing a key supply of “brain” hardware for machine learning.
  • Semiconductor Manufacturing Equipment (SME): Imposing a “presumption of denial” for licenses on export of the most advanced chip fabrication tools to Chinawww.csis.orgwww.csis.org. This covered equipment needed to produce logic chips at ~14 nm or smaller processes and DRAM at 18 nm or smaller, among others. The goal was to “block China from manufacturing advanced chips” domestically by denying it access to Western toolswww.csis.orgwww.csis.org.
  • EDA Software and Component Technologies: Controlling electronic design automation software for cutting-edge chip designs (like gate-all-around transistors) and certain semiconductor components. This was to “block China from designing AI chips domestically” by choking off critical design tools and high-end chip componentswww.csis.orgwww.csis.org.
  • U.S. Person Restrictions: For the first time, restricting U.S. persons from supporting Chinese chip development without a license. This meant American citizens or residents could not work on, or service, advanced fabrication in China. This novel measure sought to prevent American expertise from aiding China’s progress, addressing the “know-how” transfer.
  • Foreign Direct Product Rule Expansion: The new rules also expanded FDPR to cover foreign-made chips that meet the controlled specs – even if made offshore, they cannot be sold to China if U.S. technology was used in their productionwww.cnas.org. This closed loopholes by leveraging the ubiquity of U.S. chip tech. The October 7 regulations were sweeping in scope – “a massive policy shift” that ended the era of laissez-faire tech trade with Chinawww.csis.orgwww.csis.org. Notably, the rules intentionally erased the line between civilian and military uses for advanced chipswww.cnas.orgwww.cnas.org. In Sullivan’s words, for chips and supercomputing, maintaining a lead meant denying China these capabilities across the board, regardless of stated end-usewww.cnas.orgwww.cnas.org. The stated rationales in the official rule were couched in national security: to prevent China from obtaining advanced ICs for uses “contrary to U.S. national security and foreign policy interests”www.csis.orgwww.csis.org – which encompassed everything from military AI to surveillance regimes. But the strategic logic, as described by CSIS expert Gregory Allen, was broader: these actions were “not only to preserve chokepoint control but also [to] begin a new U.S. technology competition strategy”www.csis.orgwww.csis.org. In effect, the U.S. moved to “preserve its lead at all costs” in the race for AI-centric computing power.Impact and Reactions: The immediate impact in late 2022 was significant. Chinese tech companies scrambled – for instance, Alibaba and Tencent, which rely on GPUs for cloud AI services, had to halt certain upgrades. Prices for high-end graphics cards in China spiked overnight as consumers and firms hoarded what stock was leftwww.csis.orgwww.csis.org. U.S. firms, meanwhile, braced for a financial hit – Nvidia, for example, stood to lose an estimated $5.5 billion in potential revenue due to the inability to sell its flagship AI chips to Chinawww.reuters.comwww.reuters.com. (Nvidia quickly began developing China-specific lower-performance chips – like the A800 and H800 – that could pass the new thresholds, illustrating how industry tried to adapt within the

(Continued) Timeline of Key Policy Developments (2018–2023)

… The impact and reactions to the October 2022 rules were significant. Chinese tech giants like Alibaba and Tencent scrambled to secure alternative hardware, and prices for certain Nvidia graphics cards (sought for AI) surged among Chinese consumerwww.csis.org】. U.S. companies warned of lost sales – Nvidia alone estimated a potential $5.5 billion revenue impact from inability to sell its flagship AI chips to Chin】. In response, Nvidia and others began developing China-tailored chips that had capped performance to stay just within allowed limit】. These workarounds sought to mitigate commercial loss while technically complying. Critics in industry and some think tanks (like ITIF) argued such broad controls could inadvertently spur China’s indigenization and deprive U.S. firms of revenue needed for R&】. Proponents, however, believed cutting China off at the top end would slow its AI progress enough for the U.S. to extend its lead – a bet that was far from certain.2023 – Allied Coordination and “Small Yard, High Fence” in Practice: By early 2023, the U.S. had successfully brought key allies on board with its semiconductor restrictions, addressing a major potential loophole. In late January 2023, after months of diplomacy, *the Netherlands and Japan agreed (in principle) to align with U.S. export controls on advanced chipmaking equipmentwww.csis.orgwww.csis.org】. The Netherlands (home of ASML, the only maker of EUV lithography machines) and Japan (home to Nikon, Tokyo Electron, etc.) are crucial to deny China alternative sources. While details remained secret, it meant ASML’s cutting-edge EUV tools and Japan’s most advanced lithography and etching equipment would not be sold to China, thereby closing the biggest gap in the October rulewww.csis.org】. This allied coordination was framed as necessary because if the U.S. acted alone, others could fill the vacuum in China’s market – but now the “top three” suppliers were united, ensuring China couldn’t get the tech elsewherwww.csis.orgwww.csis.org】. U.S. officials touted this as vindication of the strategy: *“the gamble paid off”www.csis.org】. China’s reaction was furious yet constrained – it used economic coercion tools (like trade restrictions on Dutch and Japanese firms, and later in 2023 export curbs on critical minerals like gallium and germanium) to retaliat】. Still, Beijing couldn’t reverse the allied bloc’s decisions. In March 2023, China’s President Xi Jinping pointedly stated that the West’s containment efforts had made technological self-reliance a top priority, rallying domestic industry to “break through” the blockade.Domestically, October 2023 saw the Biden Administration update and tighten the export rules further. On October 17, 2023 (almost exactly a year after the initial rules), BIS issued updated regulations that “finalized and substantially tightened” the October 7 controlwww.csis.org】. These refinements closed technical loopholes (for instance, lowering the performance thresholds to catch China-specific chips like Nvidia’s A800 which had been designed to skirt 2022 rules). BIS also added more Chinese firms (like AI startup Biren Technology and others designing GPUs domestically) to the Entity List to ensure they couldn’t procure slightly lower-grade chips either. Furthermore, the U.S. clarified rules to cover **advanced chip substrates and other components being used to assemble high-end computing systems in China. By end of 2023, the U.S. made explicit that even AI chips used for cloud services accessible to China were under scrutiny, extending control to “cloud computing” exports (an emerging vector for China to access AI capability without importing chips directly). Commerce Department officials described China as attempting to *“divert a lot of civilian technologies… into supercomputers for civil-military fusion…and surveillance”】 – thus justifying the comprehensive tightening as directly aimed at this “far-reaching challenge】.Summary of Major U.S. Actions (2018–2023):
To synthesize this timeline, the following table summarizes key developments, actors, and stated rationales:

Date/PeriodAction/PolicyKey ActorsStated RationalesOutcomes/Notes
2018Export Control Reform Act (ECRA) enactedU.S. Congress (bipartisan)Identify & control “emerging and foundational” tech for national securit】; counter tech transfer to China’s militar】.Provided legal basis for new controls; launched process to define critical tech (AI, chips, etc.).
2019Huawei & affiliates on Entity List (May); initial AI chip license denialsTrump Admin; Dept. of Commerce (BIS)Nat’l security: Huawei posed espionage risk & aided PRC militar】. Prevent China’s misuse of AI/HPC for WMD or repression.Huawei cut off from U.S. chips (phone sales plunge); China’s 5G champion hobbled. China accelerates domestic chip design efforts as workaround.
2020Military End-Use (MEU) rule expansion (April); Foreign Direct Product Rule against Huawei (May/August)Trump Admin; BISNat’l security: Close loopholes where “civilian” trade aids PLA via MC】. Preserve U.S. lead by ensuring China stays 2 generations behind.SMIC & others targeted; Huawei’s access to TSMC chips blocked. Export control extraterritorial reach (FDPR) established a powerful preceden】.
2021NSCAI Final Report (Mar); new Entity List additions (supercomputing orgs); Supply Chain Review (Jun)NSCAI (Eric Schmidt); Biden Admin; BISTech leadership & nat’l security: “Boils down to semiconductors” – keep China two generations behin】. Limit AI chips for military/civil fusion uses.Recommendations for choke point controls on SME adopted in spirit. U.S. doubles down on “small yard, high fence” – few key techs (like EUV tools, AI chips) singled out.
Oct 7, 2022Landmark BIS rules on Advanced Computing & Semiconductor EquipmentBiden Admin; Nat’l Security Council; BISNat’l security & techno-competition: “Strangle” China’s AI and supercomputing by denying high-end GPU】. Maintain “as large a lead as possible” in chip】. Human rights: address chips used in surveillanc】.China’s AI firms lose access to best chips; U.S. firms lose China sales (Nvidia et al.). Marked start of U.S. tech containment strategy; partial decoupling in semiconductors begins.
Jan 2023U.S.-Japan-Netherlands deal on SME export controlsBiden Admin; Dutch & Japanese Govts.Nat’l security & allied unity: Present a united front so China can’t import from elsewhere; protect shared technological edgwww.csis.org】.ASML and Japanese toolmakers stop sales of top equipment to China. China protests, explores retaliations (e.g., rare earths, minerals).
Oct 2023BIS updates tightening rules (closing loopholes; more Entity List additions)Biden Admin; BISNat’l security (cont.): Prevent workaround via modified chips (e.g., Nvidia A800). Reiterate *MCF and human rights concerns】.Nvidia’s “China-custom” chips (A800/H800) now potentially in scope; further chill on China’s AI training capabilities.

This timeline underscores an evolution from targeted, case-by-case controls to a sweeping strategic approach. Initially, the focus was stopping direct military end-use (a narrower national security logic). Over time, justifications expanded to include maintaining a broad technology gap (techno-competition logic) and even an element of economic security (ensuring U.S. supply chain resilience and leverage, as emphasized in the CHIPS Act and Sullivan’s doctrine).

Shifting Rationales: National Security vs. Economic vs. Technological Competition

One of the core dynamics in this history is how the rationales for export controls have been framed and re-framed by various actors. Below, we categorize and trace these logics:

National Security Logics

Military Applications and Dual-Use Concerns: From the start, national security has been the foremost justification. Advanced semiconductors are dual-use – they power both consumer devices and military systems. U.S. officials repeatedly voiced concerns that China could use high-end American chips in weapons, surveillance, or to enhance its military AI capabilities (like autonomous drones or cyber warfare). The expansion of China’s military-civil fusion erased clear distinctions, so the U.S. began treating even ostensibly civilian tech exports as potential military enablers】. For example, Gina Raimondo (Commerce Secretary) often cited China’s blurring of civilian/military R&D as a reason for all-encompassing chip controls. By 2023, a Commerce official noted China tries to “divert a lot of civilian technologies… into supercomputers in civil-military fusion programs”, including for **“surveillance that link with human rights abuses”】. This frames export controls as not just protecting U.S. military advantage, but also preventing U.S. tech from enabling oppressive practices (tying into values-based arguments about not abetting genocide or authoritarian surveillance). The national security rationale has thus broadened: it started with concerns like (1) nuclear weapons research & missile technology (e.g., why supercomputing chips were barred), (2) military command, control, communications & intelligence (C4ISR) (need to deny China chips that could give an AI edge in conflict), and (3) human rights (preventing chips from powering China’s AI surveillance state in Xinjiang and beyond).“Chokepoint” Strategy to Degrade Adversary Capabilities: Influential voices like the NSCAI and officials like Sullivan added another layer: use export controls proactively to slow an adversary’s overall tech advancement. Sullivan explicitly said robust controls can *“impose costs on adversaries, and even over time degrade their battlefield capabilities”】. The Russia example (2022) – where controls forced Russia to scavenge for chips – became a proof-of-concept that informed the China approac】. Thus, by late 2022, the national security logic was not just defensive (protect U.S. tech), but offensive – to hamstring China’s future military potential by cutting off inputs. This is essentially a long-term denial strategy: e.g., deny PLA developers access to AI model training chips now, so that in 5–10 years the PLA’s AI systems are generations behind. The U.S. DoD and National Security Council have supported this line, often couched as buying time in the military competition with China.

Economic Competitiveness and Supply Chain Resilience

Maintaining a Technological Lead = Economic Strength: While couched in security terms, many justifications also emphasize the economy. Cutting-edge chip tech is seen as the engine of future industries (AI, quantum, advanced manufacturing). “Leadership in these is a national security imperative,” Sullivan note】. Policymakers argue that whoever leads in AI and semiconductors will reap outsized economic gains and standard-setting power. Thus, export controls are partly about preserving U.S. economic competitiveness by slowing a rival’s rise. This is a shift from older thinking – previously, economic logic argued against controls (free trade maximizes innovation and market share). Now, the logic is that certain tech is so critical that allowing China to catch up would ultimately undermine U.S. economic dominance. The CHIPS and Science Act of 2022 which poured $52B into domestic chip manufacturing, was one side of this coin (a positive industrial policy), while export controls were the other (a defensive measure】. Both were promoted as necessary for U.S. economic security.“Supply Chain Security” and Overreliance Concerns: The 2021–2022 supply chain disruptions (pandemic-driven chip shortages) also factored in. It alarmed U.S. policymakers that so much chip production was in Asia (Taiwan, South Korea) and that the U.S. was dependent on potential adversaries for key materials. The White House 100-Day Supply Chain Review (June 2021) highlighted this and suggested *export controls should ensure the U.S. isn’t fueling China’s advance at the expense of its own resilience】. In Sullivan’s 2022 speech, he referenced how the pandemic exposed “alarming” supply chain vulnerabilities and that “there is no way back” to the old ecosyste】. The implication: economic decoupling in chips is partly to ensure the U.S. and allies control their own destinies in this foundational tech. Indeed, by 2023, U.S. officials openly spoke of re-architecting supply chains to be oriented around the U.S. and trusted partners (friend-shoring), implicitly accepting some decoupling from China.Industry and Innovation Base Considerations: There’s a paradox in the economic logic. U.S. industry initially feared losing the huge China market, which could reduce their revenues and thus R&D budgets (potentially undermining U.S. technological leadership long-term). For example, a 2023 CSIS report noted U.S. firms lost market share and that *“over time, this loss… could undermine the competitiveness of U.S. firms”】. The Semiconductor Industry Association (SIA) and major firms lobbied for narrow controls, warning that broad ones might “chip away at American [industry] leadership”. However, over time, the U.S. government argument evolved to say short-term revenue losses are an acceptable trade-off for long-term security and tech dominance. The CHIPS Act subsidies were, in part, meant to offset these losses by boosting domestic demand. Meanwhile, officials like Commerce’s Alan Estevez suggested the U.S. must be comfortable with its firms possibly losing some China sales if it means China’s military doesn’t get the tech. By late 2023, a broad consensus in Washington (though not necessarily in Silicon Valley) held that maintaining the West’s edge in semiconductors justifies some economic sacrifice, aligning economic and security rationales.

Technological Competition and AI Scaling Concerns

AI Compute and Scaling Laws: A unique aspect of recent export controls is their focus on computing power for AI – essentially trying to govern the trajectory of AI development in China by throttling “access to compute.” This reflects growing awareness of machine learning scaling laws: the more powerful chips and larger datasets you have, the more advanced AI models you can train. Frontier AI development (like large language models and next-gen AI for military use) requires enormous computational resources, usually delivered by state-of-the-art GPUs or AI accelerators. U.S. policymakers, informed by think tanks like CSET and others, recognized that advanced GPUs (like Nvidia A100/H100) are crucial strategic assets because they enable training of cutting-edge AI models (from autonomous drone swarms to AI surveillance analytics). Thus, the 2022 export controls explicitly targeted general-purpose GPUs optimized for AI – a novel focus. CSET’s analyses in 2022–2024 often discussed how limiting China’s access to “AI compute” could slow its progress in large model A】. At the same time, CSET warned that if the controls were too broad (e.g., inadvertently covering CPUs that have AI feature】), it could push China to double down on domestic innovation or adopt alternative chip architectures.“Small Yard, High Fence” vs. “Growing Yard”: Initially, officials described the controls as covering a small number of most-critical items (like top-tier chips and tools) – the small yard. But technology evolves quickly, and by 2023, it was clear the yard had to expand (e.g., lowering thresholds, adding CPUs with AI accelerators to the lis】). CSET called this the “growing yard” phenomenon – as AI technology diffuses into more products, the controls catch more items than first intende】. For instance, advanced CPUs started integrating AI cores, and suddenly even Intel or AMD general processors could breach control limits. Policymakers had to decide whether to carve those out or not, balancing the competition logic (don’t give China any edge) against practical industry impact. Over time, the logic of staying “as far ahead as possible” technologically has mostly won out, resulting in expanding controls. There is an implicit recognition that AI is a game-changer – if China were to surpass the U.S. in AI capabilities due to unfettered access to compute, it could translate to both economic and military dominance in the future. This specter drives the techno-competition rationale strongly.Academic and Think Tank Perspectives: Many scholars and think-tank experts supported the goal of maintaining U.S. lead but debated the means. Some at CSIS, CNAS, and Brookings backed strict controls but urged coupling them with domestic R&D investment (since *“export restrictions alone cannot substitute for comprehensive industrial policy”】). Others warned of diminishing returns: if China is determined and capable, it will eventually find alternatives or innovate around controls (e.g., using chiplet architectures, open-source designs, etc.). A CNAS commentary by Paul Scharre (Jan 2023) argued that denying chips now might accelerate China’s drive for self-sufficiency and that a better long-term strategy is keeping China dependent so the U.S. can withhold tech as leverage in a crisi】. This was a minority view in policy circles; the prevailing view became that once China was near-peer, dependence-as-leverage was too risky, and it was better to cut them off preemptively. The debate illustrated a tension between short-term vs. long-term thinking in technological competition.

Human Rights and Ethical Considerations

While not as central as security/economic reasons, the U.S. government increasingly folded ethical arguments into export control justifications. The use of American technology (like Intel and Nvidia chips) in China’s mass surveillance of Uyghurs and other minorities was widely reported in late 2010s. Congress and human rights groups pushed for action. In 2019, several Chinese AI surveillance firms (e.g., Hikvision, SenseTime, Megvii) were added to the Entity List for human rights reasons. These moves signaled that export controls were also a tool to address values – ensuring U.S. technology isn’t complicit in atrocities. The October 2022 rules mentioned preventing chips for “surveillance and repression” as part of foreign policy interests. By framing it thus, the administration could rally broader support (it’s harder to object to a policy aimed at not abetting human rights abuses). However, cynics might note this rationale often aligned with strategic interest – i.e., the same chips that power surveillance also power military AI. Nonetheless, it’s a notable part of the narrative: the U.S. is positioning its tech policy as upholding a liberal order against authoritarian misuse of tech.

Achievements vs. Original Goals: Has the U.S. Strategy Worked?

After several years of escalating controls, it’s important to evaluate: To what extent has the U.S. achieved its initial goals, and have those goals shifted?Original Goals (implicit and explicit): Early on (2018–2019), the goals were narrower: (1) Protect U.S. national security by denying China tech that would directly bolster its military or surveillance state. (2) Induce China to play fair on tech (e.g., reduce IP theft, abide by rules) by demonstrating U.S. willingness to withhold key tech. (3) Maintain a relative edge (2-generation lead) in key dual-use technologies. By 2022, the goals expanded to: (4) Freeze China’s progress in AI and advanced computing where possible (i.e., slow them down enough that the U.S. can extend its lead). (5) Safeguard U.S. supply chain security and reduce critical dependencies on China. (6) Coordinate an allied tech denial regime to present a united front.Achievements:

  • Slowing Chinese Military AI/Advanced Computing: The U.S. has undoubtedly impaired China’s near-term capabilities in certain areas. For instance, China’s leading AI firms like SenseTime and Baidu can no longer readily obtain top GPUs, which has reportedly forced them to use larger clusters of older chips – less efficient for training large AI models. Chinese supercomputers that might be used for nuclear simulation or hypersonics R&D face delays or performance limitations without access to U.S. accelerators. As one metric, China’s placement in the TOP500 (a ranking of supercomputers) saw fewer new entrants after 2020, possibly due to difficulty obtaining parts. Chinese military programs that rely on high-end chips (from satellite imagery analysis to advanced radar) likely have had to make do with less optimal hardware, which could slow development. So in the short run, goal (1) – slowing military AI progress – has been partly met. However, China is adapting; e.g., Huawei’s 2023 release of a 7nm smartphone chip made domesticallywww.csis.org】shows it is finding ways to innovate under sanctions, albeit at higher cost and slower pace.
  • Maintaining/Extending Tech Lead: The U.S. still leads in cutting-edge chip design (Nvidia, AMD) and semiconductor manufacturing equipment (Applied Materials, Lam, KLA). By denying China access, the U.S. and its close allies (Taiwan’s TSMC, South Korea’s Samsung) continue to operate roughly 2+ generations ahead of China’s best. China’s most advanced logic chip production is stuck at ~7nm (with heavy yield issues), whereas TSMC/Intel/Samsung are moving to 3nm and below. This suggests the goal of keeping China a couple generations behind is being achieved so far. Moreover, the U.S. “big three” EDA software firms (Cadence, Synopsys, Mentor) withdrew support from Chinese customers, making it harder for China to design at the leading edge. An important caveat: these achievements are holding actions. China is investing heavily in catching up, and some experts caution that export controls only buy time unless the U.S. also runs faster (invests in its own innovation). The U.S. has ramped up R&D funding via the CHIPS Act and related initiatives, which can be seen as part of achieving the spirit of the goal (extend lead via both denying adversary and boosting oneself).
  • Allied Coordination: Initially, a big risk was that unilateral U.S. controls would fail if allies didn’t cooperate. By securing deals with the Netherlands, Japan (and effectively South Korea and Taiwan’s informal compliance), the U.S. built a coalition controlling the choke points. This is a significant diplomatic achievement. The trilaterial agreement (U.S.-NL-Japan) in early 2023 was critical in blocking China’s lithography access. There is still work to fully align (the deal wasn’t public or formal, and each country implemented it slightly differently), but goal (6) – allied coordination – is on track. European Union-wide controls are slower (due to consensus issue】), but key member states are acting. The U.S. also managed to get Taiwan to enforce the Foreign Direct Product rule, plugging a huge ga】. Without ally support, Chinese firms could have backfilled via Dutch/Japanese suppliers; that door is largely closed. So, in that sense, the U.S. achieved a major original goal by mid-2023.
  • Chinese Tech Behavior: If one goal was to pressure China to curb IP theft and unfair practices, the results are less clear. China did pass new IP laws and eased joint-venture pressure in 2020-21 (partly due to the Phase One trade deal), but it hasn’t fundamentally altered its strategic course (Made in China 2025 ambitions quietly continue). Export controls arguably hardened China’s resolve to pursue self-reliance more aggressively rather than making it more accommodating. There is little evidence that China has become a more responsible tech player due to these measures – instead, tech has become even more politicized in the rivalry.
  • U.S. Supply Chain Resilience: By making Chinese components and equipment off-limits, U.S. and allied firms have had to diversify their supply chains. The CHIPS Act investments will yield new fabs in the U.S. (though not at leading edge initially, mostly 5-10nm processes). Goal (5) of reducing dependency on China is gradually progressing: e.g., TSMC and Samsung are building fabs in Arizona and Texas, respectively, which in a few years will lessen reliance on Asian production. However, this is a medium-term outcome. In the short term, U.S. industry had to adjust to lost Chinese inputs for certain low-end chips or materials. Interestingly, China’s 2023 retaliation (restricting exports of gallium and germanium – key for chipmaking) showed that the U.S. still depends on China for some upstream inputs, an area that needs work. Redefinition or Continuation of Goals: Current arguments for maintaining or expanding controls seem to be a continuation of the later goals with some refinement:
  • From Maintaining a Lead to Maximum Isolation: Initially, the phrasing was “a couple generations ahead” (relative lead). Sullivan’s doctrine changed that to “as large a lead as possible】. That suggests the goalposts moved – now it’s not enough that China is behind; it should remain indefinitely behind in critical domains. This is effectively a redefinition from maintain an edge to actively ensure China cannot catch up. The October 2022 rules were the inflection of that new goal.
  • Economic Security as Security: Whereas earlier arguments balanced economic interests, now officials equate economic competitiveness with national security. The term “techno-security” strategy is apt – ensuring America’s technological base (which underpins economic strength) is secure from being hollowed out by China. So, the goal has been broadened: not only deny China, but also rebuild domestically. In speeches, Biden officials often mention export controls in the same breath as the CHIPS Act, implying the real goal is a healthier U.S. tech ecosystem that doesn’t feed a rival’s rise. Thus, maintaining controls now is sold as essential for American innovation leadership, not just a defensive move.
  • AI Governance and Global Norms: Another emerging rationale (post-2023) is the idea that the U.S., by controlling AI tech diffusion, is trying to set global rules for AI. The Carnegie Endowment has written about the U.S. attempt to “govern AI’s global spread” via export control】. In other words, if AI is the transformative tech of our era, whoever controls the top AI compute can influence how and where AI is developed responsibly. This is a more nuanced, strategic rationale – blending traditional security with a form of technological statesmanship. It’s somewhat new and can be seen as a redefinition of goals: from just slowing China to also shaping the trajectory of AI worldwide (with an implicit stance that authoritarian AI development should be constrained). Unintended Effects and Challenges: It is also worth noting areas where goals have not been fully met or new challenges have arisen:
  • Chinese Acceleration and “Malign Competitiveness”: Far from giving up, China responded to controls with massive state investment in semiconductors. By 2023, China’s government set up multi-billion dollar funds (the “Big Fund” II, etc.), and local firms made breakthroughs like YMTC’s 3D NAND memory chips and Biren’s domestic AI chips (though Biren was added to the Entity List to stymie them). Some experts fear that export controls could spurr “leapfrogging” – China might find novel approaches that bypass Western tech, which could surprise the U.S. For example, if China achieves a breakthrough in chip architecture or quantum computing, the whole paradigm of control might shift. This was pointed out by CSIS: *“doubling down on deeply subsidized development efforts… could produce breakthrough technologies… potentially destabilizing the U.S. semiconductor ecosystem”】. So while goals are met in short term, the long-term is an open question.
  • Gaps and Enforcement Issues: The U.S. found that enforcing such broad controls globally is hard. There have been reports of smuggling and diversion – e.g., chips shipped to subsidiaries in third countries then rerouted to Chin】. Chinese traders turned to the gray market. Policing this requires significant resources and international cooperation. The U.S. has ramped up enforcement (the Justice Department’s “China Initiative” initially, now a broader effort targeting export evasion), but ensuring compliance in places like Southeast Asia is challenging. Thus, achieving the goal of comprehensively denying China is tough – some leakage occurs. The current argument to maintain controls acknowledges these gaps but posits that tightening loopholes and aligned ally rules (e.g., closing the UAE re-export hub) can mitigate it.
  • Impact on U.S. Firms and Innovation: As anticipated, U.S. companies did take a hit. The longer-term effect on their R&D is not yet fully known. Some argue that loss of the China market could reduce U.S. chip firms’ ability to invest in future technology, ironically harming the goal of maintaining a lead. The Biden Administration has tried to address this via subsidies and by expanding markets elsewhere (encouraging sales to India, for instance). If over the next few years U.S. firms still lead in revenues and innovation, then the strategy will be validated. But if they slip while China’s subsidized competitors catch up in older tech (and then maybe in new tech), the U.S. might have to reassess the balance of controls vs. competitiveness. Continuity vs. Redefinition: So far, the arguments for maintaining or expanding controls (as of 2024-2025) seem to be a continuation of the approach begun in 2022, rather than a complete redefinition. They emphasize that the job isn’t finished: China still aspires to lead in AI and chips by 2030s, so the restrictions must stay or even tighten until China’s ambitions are “managed.” Some shifts in tone include more open talk of tech containment (though officials avoid that term publicly, preferring “protecting our advantages”). If anything, the framing has shifted from a defensive crouch (circa 2018: “we need to stop helping China’s military”) to a more assertive stance (circa 2024: “we will do whatever it takes to ensure China remains behind us in tech”). This is a continuum, not a U-turn.

Coordination with Allies: A Multilateral Web of Controls

As noted, ally coordination is a linchpin of success. After the 2023 alignment with the Netherlands and Japan, focus turned to integrating more allies:

  • Taiwan and South Korea: These are home to TSMC, Samsung, SK Hynix – essential chip producers. They have mostly complied with U.S. rules (e.g., SK Hynix and Samsung were given waivers to continue operating fabs in China at certain technology levels, but agreed not to advance them). Taiwan publicly supported the FDPR applicatio】. Their cooperation has been driven by a mix of U.S. pressure and their own self-interest in constraining a potential Chinese competitor. However, both are wary – they want to continue selling older-gen chips to China (a huge market for those), so the U.S. has had to calibrate allowances.
  • Europe (EU): The EU as a bloc hasn’t fully matched U.S. controls, partly due to internal division. The Netherlands was key (with ASML), and once it acted, Europe’s leverage decreased. The EU is considering new legal authority to do export controls collectivel】, but that’s slow. Meanwhile, countries like Germany have significant trade with China and are cautious. Still, Europe’s biggest tech players (like ASML, Nokia/Ericsson in 5G, etc.) are on guard and often follow U.S. export guidance informally. The U.S.-EU Trade and Tech Council facilitates some of this discussion. The U.K. and Canada have mirrored some U.S. moves too (e.g., blocking Chinese investment in chip firms).
  • Japan: In 2023, Japan announced its own set of export restrictions on 23 types of chip-making technology, which align closely with U.S. goal】. Unlike the U.S., Japan’s approach doesn’t single out China by name – it’s couched generally, but everyone knows the intent. Japanese industry had concerns (China is a top market), but Tokyo balanced this with the recognition that Japan’s security is directly tied to U.S. tech leadership in any conflict scenario. Ally Challenges: Despite progress, differences remain. As CSIS noted, allies often have narrower controls and do not want to apply extraterritorial rules like the U.S】. For instance, a Japanese firm could in theory ship from a subsidiary outside Japan to skirt domestic controls, though doing so risks U.S. retaliation or loss of U.S. partnership. The U.S. also had to address South Korea’s concerns: SK Hynix and Samsung have huge fabs in China and billions at stake. The U.S. gave them time-limited waivers to continue operations. By 2025, those waivers need extension or adjustment, a delicate point in ally coordination.Global Semiconductor Order Reshaped: The collective result of these allied efforts is that China is now largely isolated from the cutting edge of the global semiconductor supply chain. It can still import older-generation tech freely (for now), which is why Chinese companies are turning to mature nodes (28nm, 40nm) – good enough for many applications but not high-end AI. The goal for allies is to hold that line and push it forward as tech advances (i.e., today 14nm is cutoff, tomorrow it might be 28nm as the world moves to 2nm). This is a moving target.

Conclusion: The New Status Quo and Future Outlook

What began as targeted export restrictions has evolved into a broad strategic doctrine: the U.S. and its allies are actively preventing China from obtaining the most advanced semiconductors, not just for immediate security reasons, but to shape the long-term balance of power in technology. The justifications have intertwined national security with economic and technological competition rationales, making export controls a central tool of Great Power competition policy.Continuation of Original Goals: The core original goals – protect U.S. security, maintain a tech lead – remain, but they have been amplified. The U.S. has largely met near-term aims (Chinese advanced tech progress slowed, U.S. lead sustained), but faces the task of sustaining this over years. Current arguments for keeping or even widening controls emphasize:

  • The job is not done – China is investing massively to overcome these barriers, so relaxing now would squander the progress.
  • The threat environment has, if anything, worsened – e.g., China’s military advances like hypersonic tests (2021) and aggressive moves mean tech denial is as critical as ever.
  • Controls are part of a broader strategy including domestic revival (CHIPS Act) and ally networks (Chip 4 alliance with Taiwan, Japan, Korea). Removing one leg (controls) would undermine the whole.
  • Ethically, it remains imperative to ensure U.S. tech isn’t fueling potential adversary militaries or human rights abuses. Redefinition of Goals: Subtly, some goals have indeed been redefined: rather than just slowing Chinese military AI, some officials hint at ensuring the U.S. decisively outpaces China in AI. Instead of just maintaining a lead, it’s now ensuring China cannot threaten that lead in critical domains. These are shifts in degree, reflecting confidence that the U.S. can and should use its leverage to the maximum extent.Effectiveness and Long-Term Risks: The U.S. strategy’s effectiveness long-term is debated. If judged up to 2023, it successfully imposed significant costs on China’s tech secto】 – causing short-term disruption, and compelling China to pour resources into catching up. Some fear this might actually galvanize China’s tech self-sufficiency (the “Sputnik” effect for China), eventually eroding U.S. advantages if China manages to innovate around U.S. inputs. Others believe China’s dependence on Western tech was a vulnerability that had to be exploited eventually, and doing so now while the U.S. holds clear advantages is wise – even if it accelerates China’s efforts, starting from behind is hard due to the complexity of semiconductor ecosystems. The truth may be mixed: we might see China achieve partial success in some areas (like memory chips or older node logic) but struggle in others (EUV lithography, cutting-edge GPUs) for a prolonged period. Meanwhile, U.S. controls will have to continuously adapt to technology changes (e.g., new AI paradigms beyond GPUs, potential developments in chiplet architectures or optical computing that might circumvent current definitions).Concluding Note: The semiconductor export controls against China from 2018 to present represent a landmark in the intellectual history of tech policy – a shift from post-Cold War laissez-faire globalization toward technological containment and strategic decoupling in certain key sectors. They blur the lines between economic policy and national security policy. Think tanks have variously lauded this as necessary and overdue, or cautioned against overreach that could undermine U.S. innovatio】. The White House and Commerce Department maintain that this course is a *“grand vision” over five or six years】 to secure the free world’s technological edge. As of 2025, the new status quo is one of persistent tension: the U.S. leveraging its semiconductor chokehold to constrain China, and China undertaking a whole-of-nation effort to break that chokehold. The coming years will reveal whether this strategy results in a stable advantage for the U.S. (a continued “silicon separation” favoring the West), or whether it triggers a technology sprint that eventually diminishes U.S. influence in global semiconductor standards and markets.Either way, the export controls have fundamentally redefined U.S.-China relations in technology. The era of relatively unfettered exchange is over; we are in an era where strategic competition in AI and chips shapes trade rules. The intellectual justification for this – balancing national security with economic-technological competition – will likely influence other domains, from quantum computing to biotechnology, as the U.S. applies the lessons learned in the semiconductor “small yard, high fence” saga.