HOTTechCrunchMarch 6, 2026🇺🇸 USTrade
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US Chip Export Controls: License Screening

The US is reportedly considering sweeping new chip export controls. BIS regulates semiconductor exports under EAR based on TOPS, technology node, and destination. Use this tool to screen whether your chip requires a license.

Concept Fundamentals
4,800
TOPS Threshold
AI chip limit
14nm
Tech Node
Restricted for D1
China, Russia
D1 Countries
Strictest

Ready to run the numbers?

Why: Chip export controls are complex and change frequently. A single parameter (TOPS, node, destination) can determine whether you need a license. This calculator helps you screen before engaging legal counsel.

How: We apply BIS EAR logic: TOPS > 4800, technology node < 14nm, destination tier, and end-use screening. Results are indicative only; formal classification requires BIS or legal review.

Sources:BIS EARCommerce Dept

Run the calculator when you are ready.

Screen Your Chip ExportUse the calculator below to see how this story affects you personally

Quick Examples

Nvidia H200 to China

High-performance AI chip exceeding TOPS threshold for restricted destination.

AMD MI325X to India

Data center AI accelerator to allied nation. May qualify for license exception.

Consumer GPU to EU

Consumer gaming GPU below TOPS threshold. Generally no license required.

Edge AI Chip to Singapore

Low-power edge inference chip to D5 country. Low risk.

FPGA to Taiwan

Programmable logic for manufacturing. Taiwan is D5; check end-use.

Custom ASIC to Saudi Arabia

Custom AI chip for oil & gas. D3 country with military end-use scrutiny.

Chip Specifications

Trillion ops/sec
e.g. 5, 7, 14

Export Details

License Required
5nm node restricted for D1 destinations; Memory bandwidth (900 GB/s) combined with TOPS triggers control; Destination China is D1 (highest restriction tier)
Classification: 3A090
Risk: restricted
Processing: 8 weeks
Penalty Risk: Very High

Screening Summary

Chip Type:GPU
TOPS:3000
Tech Node:5nm (restricted)
Destination Tier:D1

Compliance Checklist

  • Obtain BIS commodity classification
  • Screen end-user against Entity List
  • Document end-use and end-user
  • Apply for license or verify exception

Alternative Options

  • Consider D4/D5 destination or downgraded specs
Last verified: March 6, 2026 | Sources: TechCrunch, BIS, Commerce Dept

Export License Screening

LicenseRequired\text{License} \text{Required}

5nm node restricted for D1 destinations; Memory bandwidth (900 GB/s) combined with TOPS triggers control; Destination China is D1 (highest restriction tier)

For educational and informational purposes only. Verify with a qualified professional.

What Are US Chip Export Controls?

The Bureau of Industry and Security (BIS) regulates semiconductor exports under the Export Administration Regulations (EAR). Chips exceeding performance thresholds (TOPS, technology node, memory bandwidth) or destined for restricted countries require export licenses.

TOPS Threshold (4,800)

AI chips exceeding 4,800 TOPS at FP16 or equivalent precision are controlled under ECCN 3A090. The threshold was established in October 2022 and applies to exports to China, Russia, and other D1 countries.

Technology Node Restrictions

Chips manufactured at 14nm or below are restricted for D1 and D3 destinations. This includes logic chips, memory, and certain FPGAs. Wafer-level packaging and advanced interconnects may also trigger controls.

Destination Country Tiers

BIS groups countries by restriction level. D1 (China, Russia, Iran, North Korea) faces the strictest controls. D5 (EU, UK, Japan, Taiwan, Singapore) generally has fewer restrictions for commercial chips.

D1: China, Russia, Iran, NK
D3: Saudi Arabia, UAE
D4: India, Israel, Korea, Japan
D5: EU, UK, Taiwan, Singapore

End-Use and End-User Screening

Military, surveillance, or nuclear end-uses trigger additional controls. Government end-users in certain countries require enhanced due diligence. Screen against the Entity List, Denied Persons List, and Unverified List before export.

ECCN Classification

3A090 covers advanced computing chips; 4A090 covers supercomputer components. Use the BIS Commodity Classification Automated Tracking System (CCATS) or consult a trade compliance professional for formal classification.

3A090: Integrated circuits with >4800 TOPS or >600 GB/s interconnect

4A090: Computers containing 3A090 chips

EAR99: Most items not listed elsewhere; no license for most destinations

License Exceptions

License Exception ENC may apply for encryption-capable chips. TSU covers mass-market software. Some civil end-uses in D4/D5 may qualify for license exceptions. Always document your exception eligibility.

Penalties and Compliance

EAR violations can result in civil penalties up to $300,000 per violation, criminal prosecution, and denial of export privileges. Implement a robust export compliance program including screening, training, and recordkeeping.

  • Civil: Up to $300,000 or twice transaction value per violation
  • Criminal: Fines and up to 20 years imprisonment for willful violations
  • Denial order: Prohibition on future exports

Re-export and De minimis Rules

US-origin content in foreign-made products may trigger EAR. The de minimis rule allows certain foreign products with limited US content to be exported without a license. Re-export from a foreign country to a restricted destination may still require US authorization.

CHIPS Act and Domestic Manufacturing

The CHIPS and Science Act of 2022 provides incentives for domestic semiconductor manufacturing. Export controls complement these efforts by limiting the transfer of advanced chip technology to geopolitical rivals. Companies receiving CHIPS funding must comply with additional restrictions on expansion in China.

Comparison: Screening vs Formal Classification

AspectThis CalculatorBIS CCATSLegal Counsel
PurposePreliminary screeningFormal classificationCompliance advice
BindingNoYes (for requester)Case-specific
CostFreeFreeFee-based
TurnaroundInstant30-60 daysVaries

Disclaimer: This calculator is for educational screening only. Always obtain formal BIS classification and legal advice before exporting. Regulations change frequently.

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