The U.S. Department of Commerce has published new export rules for advanced AI and HPC processors shipped to China and Macau. The new regulations do not open the Chinese market for advanced processors developed in the U.S. in general, but introduce a narrowly defined, compliance-heavy method that allows limited exports of specific products — such as AMD's Instinct MI325X, Nvidia's H200 GPUs, and similar accelerators offering lower performance — under a strict case-by-case licensing regime.
The export licenses will only be granted if the products are readily available in the U.S. and their shipments to China do not exceed shipments to American entities, which closes the doors for China-only SKUs.
Export rules for two accelerators?
The new rules are designed to enable the export of specific AI accelerators and processors offering similar performance. Therefore, eligible devices must have a total processing performance (TPP) of less than 21,000 and a total DRAM bandwidth of less than 6,500 GB/s.
The policy applies only to end-users physically located in China or Macau, and maintains a presumption of denial for re-exports and countries designated as Group D:5 entities (including Belarus, Iran, North Korea, Russia, and others).
The key constraint is that the U.S. supply must not be disrupted. Exporters must show that U.S. demand is fully met, that no domestic orders are delayed, no U.S. advanced-node foundry capacity is diverted, and that China-bound shipments do not exceed 50% of the same product shipped into the United States.
Essentially, China is now treated as a spillover market for big suppliers like AMD and Nvidia, and is restrictive for smaller companies that might wish to sell to Chinese entities. However, Europe, Japan, and other markets are treated as normal destinations under the new export controls, so the new constraints do not automatically restrict volumes shipped to customers in Europe, Japan, and other nations.
(Image credit: Nvidia)
The U.S. DoC's Bureau of Industry and Security (BIS) explicitly references AMD's Instinct MI325X and Nvidia's H200 as examples of products that may qualify, provided they meet TPP (listed dense processing power multiplied by the length of operation) and memory bandwidth limits.
For example, the MI325X has 1,300 TFLOPS of FP16 performance and has a TPP score of 20,800, whereas the H200 offers 989.5 FP16 TFLOPS and therefore has a TPP score of 15,832. As for memory, the MI325X carries 256 GB of HBM3E, with a bandwidth of 6 TB/s, whereas the H200 carries 141 GB with a bandwidth of 4.8 TB/s. As a result, both GPUs meet the requirements of the DoC's BIS and can be shipped to China or Macau, provided that the government grants the license.
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