China Semiconductor Export Regulations Episode 5 – Update
On March 29, 2024, BIS published an interim final rule (IFR) updating and correcting its October 2023 advanced computing and semiconductor regulations(1) (which we will discuss in Episode 3). This is the third such semiconductor-related regulation since the key regulations were published in October 2022 (which we will discuss in Episode 1; for background information, see posts here (Episode 2) and here (Episode 4)). This IFR is effective as of April 4, 2024. Interested parties may comment on amendments, corrections, and clarifications by April 29, 2024 here (AC/S IFR) and here (SME IFR). After reviewing 166 pages of regulations (yes, that number is correct), we highlighted some of the significant changes below. Key Takeaways Overall, these regulations skirt the edges of some controls—reducing controls and obligations on certain chip exports and expanding license coverage—but also expand the boundaries of others. However, these changes are largely at the edges of existing regulations and do not have the same transformative impact on…
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