AI Export Controls: Navigating Chip Restrictions Globally

Updated December 11, 2025

December 2025 Update: Trump administration modifying Biden-era three-tier export controls, relaxing Middle Eastern restrictions while tightening China enforcement. 65 new Chinese entities added to Entity List in 2025. H100/H200/Blackwell GPUs remain fully restricted to Tier 3 countries. Validated End User (VEU) status becoming essential for Tier 2 organizations seeking procurement above country caps.

NVIDIA's CEO Jensen Huang met with President Trump in early December 2025 to discuss export controls that have whipsawed the AI chip market for three years.¹ The regulations determine which countries can access H100, H200, and Blackwell GPUs—and by extension, which organizations can build competitive AI infrastructure. For enterprises operating globally, understanding export controls has become as essential as understanding the chips themselves.

The regulatory landscape shifted dramatically through 2025, moving from Biden administration restrictions that divided the world into three tiers to Trump administration modifications that eased Middle Eastern access while tightening enforcement against China. Organizations procuring AI hardware must navigate licensing requirements, end-user verification, and geographic restrictions that vary by chip capability and destination country.

The regulatory framework

U.S. export controls on AI chips operate through multiple overlapping mechanisms:

Bureau of Industry and Security (BIS) controls

BIS administers the Export Administration Regulations (EAR) governing technology exports. Key control mechanisms include:

Entity List: Organizations prohibited from receiving U.S. technology without special licenses. The Trump administration added 42 Chinese entities in March 2025 and another 23 in September 2025.²

Export Control Classification Numbers (ECCNs): Categories defining which products require licenses for export to specific destinations.

Total Processing Performance (TPP): Metric combining computational throughput and interconnect bandwidth to determine chip classification. The October 2023 framework established TPP thresholds that effectively blocked A100, H100, MI300X, and even some gaming GPUs like the RTX 4090 from restricted markets.³

Country classifications

The January 2025 "AI Diffusion Rule" established a three-tier country classification:⁴

Tier 1 (No restrictions): United States and 18 close allies including UK, Canada, Germany, Japan, South Korea, Taiwan, Australia, and New Zealand. Organizations in these countries face no AI chip procurement restrictions.

Tier 2 (Quantity limits): Most countries including Eastern Europe, Middle East, Mexico, Latin America, and Southeast Asia. Initial limits capped approximately 50,000 GPUs between 2025-2027, though Trump administration modifications relaxed Middle Eastern restrictions.⁵

Tier 3 (Prohibited): Approximately 20 countries including China, Russia, Iran, North Korea, and Sudan. Advanced GPU exports banned entirely without special authorization.

Validated End User (VEU) status

Organizations in Tier 2 countries can obtain higher compute capability through VEU certification:⁶ - Demonstrate compliance with U.S. regulations - Accept monitoring and audit requirements - Commit to preventing technology diversion - Provide transparency on end uses

VEU status enables procurement beyond standard country caps but requires ongoing compliance commitments.

Chips affected by controls

Fully restricted chips (Tier 3 countries)

NVIDIA: - H100 / H200 (all variants) - A100 (40GB and 80GB) - B100 / B200 / GB200 - RTX 4090 (consumer GPU meeting TPP thresholds)

AMD: - MI300X / MI300A - MI250X

Intel: - Gaudi 3

China-specific variants

NVIDIA created modified chips designed to comply with export thresholds while serving the Chinese market:⁷

A800: A100 with NVLink bandwidth reduced from 600 GB/s to 400 GB/s. Blocked by October 2023 rules.

H800: H100 with interconnect bandwidth reduced from 900 GB/s to approximately 300 GB/s. Also blocked by 2023 rules.

H20: Deliberately stripped-down Hopper variant with fraction of H100 compute capability. Initially permitted, then required licensing in April 2025, then approved for licensed sales in July 2025.⁸

Rumored B-series variant: NVIDIA reportedly developing new chip approximately half as powerful as B300 to serve Chinese market while complying with current regulations.⁹

AMD China variants

MI308: AMD's China-compliant variant of MI300 series. Follows similar pattern of reduced capability to meet TPP thresholds.

2025 regulatory timeline

The export control landscape evolved rapidly through 2025:

January 2025: Biden administration issues comprehensive "AI Diffusion Rule" establishing three-tier country framework and compute caps.

January 2025: NVIDIA strongly criticizes rules as threatening "to derail innovation and economic growth worldwide."¹⁰

March 2025: Trump administration adds 42 Chinese entities to Entity List.

April 2025: H20 sales to China suddenly require export licenses, effectively halting compliant chip sales.

May 2025: Trump administration scraps country-tiered restrictions, easing Middle Eastern access.¹¹ Saudi Arabia and UAE, previously limited to 1,700 AI chips annually, gain expanded access.

July 2025: Administration backtracks on H20 restrictions, approving licenses for H20 and AMD MI308 sales to China.

July 2025: Reports emerge of draft restrictions targeting Malaysia and Thailand over suspected chip diversion to China.¹²

September 2025: 23 additional Chinese entities added to Entity List.

December 2025: Ongoing discussions between NVIDIA leadership and Trump administration regarding export policy direction.

Enterprise compliance requirements

Due diligence obligations

Organizations procuring or deploying AI chips must:

Know your customer: Verify end-user identity and intended use for all chip transactions. Maintain documentation demonstrating legitimate business purpose.

Screen against restricted parties: Check Entity List, Denied Persons List, and other BIS restricted party lists before transactions.

Classify products: Understand ECCN classification of chips being procured and any license requirements for destination countries.

Monitor end use: Prevent diversion of chips to prohibited end users or uses, including weapons development or surveillance applications in restricted countries.

Documentation requirements

Maintain records supporting export compliance: - Purchase orders and invoices showing chip models and quantities - End-user certificates for international transactions - Destination verification for cloud deployments - Technology access logs for multinational research collaborations

Cloud deployment considerations

Export controls apply to technology access, not just physical hardware:

Cloud regions: GPU cloud instances in Tier 1 countries can generally be accessed globally, but certain model training activities may trigger deemed export concerns.

Remote access: Providing Tier 3 country nationals access to controlled technology, even via cloud, may require licenses.

Multinational teams: Organizations with employees in restricted countries should evaluate deemed export implications for AI research collaboration.

Regional implications

China

Export controls created significant but not insurmountable barriers for Chinese AI development:

Adaptation strategies: Chinese organizations developed more efficient architectures to achieve competitive results with limited hardware. DeepSeek's R1 model demonstrated "near-frontier" performance using older H800 chips through architectural optimization.¹³

Gap assessment: White House AI Czar David Sacks estimated China's AI sector lags the U.S. by three to six months—a gap widened but not created by export controls.¹⁴

Domestic alternatives: Huawei's Ascend chips and other domestic accelerators provide alternatives, though performance gaps remain versus NVIDIA hardware.

Middle East

May 2025 policy changes dramatically improved Middle Eastern access:

Previous restrictions: Saudi Arabia and UAE limited to approximately 1,700 chips annually under Biden rules.

Current status: Expanded access with VEU pathway for large-scale deployments. U.S. policy explicitly aims to attract "petrodollars" for domestic AI investment.¹⁵

Data center growth: Middle Eastern sovereign AI initiatives now have clearer procurement pathways, though compliance requirements remain.

Southeast Asia

Southeast Asia faces increased scrutiny over diversion concerns:

Malaysia and Thailand: Draft restrictions under consideration due to suspected use as transshipment points for chips ultimately destined for China.¹⁶

Singapore: Explicitly mentioned in U.S. concerns about third-country access enabling Chinese AI development.

Compliance burden: Organizations in the region face enhanced documentation requirements to demonstrate legitimate end use.

Procurement strategies

For Tier 1 country organizations

Organizations in unrestricted countries face minimal direct compliance burden but should:

• Maintain awareness of restrictions when partnering with Tier 2/3 entities
• Evaluate deemed export implications for multinational research teams
• Document end uses to support potential audits

For Tier 2 country organizations

Navigate quantity limits and VEU requirements:

Optimize allocation: Prioritize highest-value use cases within country caps. Consider whether training or inference workloads deliver better ROI given constraints.

Pursue VEU status: For large-scale deployments, VEU certification provides pathway to higher allocations despite compliance overhead.

Cloud alternatives: Tier 1 cloud regions may provide access to GPU compute without triggering procurement caps, though technology access restrictions may apply.

Diversify suppliers: AMD, Intel, and emerging accelerator vendors face similar but not identical restrictions. Multi-vendor strategies may provide flexibility.

For organizations with global operations

Multinational organizations face complex compliance landscapes:

Segment infrastructure: Maintain clear separation between operations in different regulatory jurisdictions.

Centralize compliance: Establish export control expertise accessible across business units.

Engage counsel: Complex international operations warrant specialized legal guidance on export compliance.

Organizations navigating AI chip procurement across regions can leverage Introl's global presence for compliant hardware deployment across 257 locations worldwide.

Looking ahead

Export controls remain politically contested and subject to rapid change:

Industry pressure: NVIDIA and the Semiconductor Industry Association continue lobbying for relaxed restrictions, arguing controls harm U.S. competitiveness more than they constrain adversaries.¹⁷

Enforcement evolution: Increased focus on transshipment and diversion suggests tighter enforcement even as headline policies fluctuate.

Technology response: NVIDIA's development of China-specific variants demonstrates vendor willingness to engineer around restrictions rather than forfeit markets entirely.

Geopolitical dependency: Export control policy remains tightly coupled to broader U.S.-China relations, making long-term predictions unreliable.

Strategic recommendations

For enterprises

1. Build compliance capability: Export controls affect more organizations than commonly assumed. Establish internal expertise before needing it urgently.

2. Monitor policy changes: Regulatory landscape shifts rapidly. Subscribe to BIS updates and industry analysis tracking control evolution.

3. Document everything: Comprehensive records protect against compliance inquiries and demonstrate good faith efforts.

4. Plan for uncertainty: Build infrastructure strategies resilient to policy changes. Avoid over-dependence on regulatory continuity.

For infrastructure decisions

1. Consider geographic flexibility: Deployments in Tier 1 countries face fewest restrictions and provide most procurement optionality.

2. Evaluate cloud vs. owned: Cloud deployment in Tier 1 regions may circumvent some hardware procurement restrictions, though technology access rules still apply.

3. Assess vendor diversity: Multi-vendor strategies provide resilience against vendor-specific restrictions or allocation limits.

The export control landscape for AI chips combines geopolitical complexity with rapid technological change. Organizations building AI infrastructure must treat regulatory compliance as a core competency rather than an afterthought. The chips powering AI advancement have become strategic assets subject to the same controls previously reserved for weapons systems and nuclear technology. Understanding and navigating these controls determines which organizations can access the compute capacity that AI leadership requires.

Key takeaways

For compliance teams: - Three-tier country classification: Tier 1 (18 allies, no restrictions), Tier 2 (quantity limits ~50K GPUs 2025-2027), Tier 3 (~20 countries, prohibited) - Due diligence requirements: know your customer verification, Entity List screening, ECCN classification, end-use monitoring for diversion prevention - Cloud deployment triggers export controls: technology access applies regardless of physical hardware location; deemed export rules affect multinational teams

For procurement teams: - Fully restricted chips (Tier 3): H100/H200, A100, B100/B200/GB200, RTX 4090, MI300X/MI250X, Gaudi 3 - China variants: H20 (stripped-down Hopper, licensed July 2025), A800/H800 (blocked October 2023), rumored B-series half-power variant in development - Tier 2 countries: pursue VEU certification for higher allocations; cloud alternatives in Tier 1 regions circumvent some procurement caps

For legal/regulatory teams: - 2025 timeline: Biden AI Diffusion Rule (January), Trump modifications easing Middle East (May), H20 license approval (July), Malaysia/Thailand scrutiny (ongoing) - Entity List additions: 42 Chinese entities (March 2025), 23 more (September 2025); enforcement tightening on transshipment/diversion - Documentation requirements: purchase orders, end-user certificates, destination verification, technology access logs for multinational research

For regional operations: - China adaptation: DeepSeek achieved near-frontier performance with H800 through architectural optimization; domestic alternatives (Huawei Ascend) remain inferior - Middle East expansion: Saudi Arabia/UAE gained expanded access under Trump policy shift; VEU pathway enables large-scale deployments - Southeast Asia risk: Malaysia, Thailand, Singapore face draft restrictions over suspected transshipment; enhanced documentation requirements emerging

For strategic planning: - Build compliance capability before urgent need; export controls affect more organizations than commonly assumed - Geographic flexibility: Tier 1 country deployments face fewest restrictions; multi-vendor strategies provide resilience - Policy remains politically contested and coupled to U.S.-China relations; plan for uncertainty and avoid regulatory continuity dependence

References

1. Tom's Hardware. "Nvidia lobbies White House and wins loosened AI GPU export control to China." December 2025. https://www.tomshardware.com/tech-industry/artificial-intelligence/nvidia-lobbies-white-house-and-wins-loosened-ai-gpu-export-control-to-china-u-s-lawmakers-reportedly-reject-gain-ai-act

2. EveryCRSReport. "U.S. Export Controls and China: Advanced Semiconductors." 2025. https://www.everycrsreport.com/reports/R48642.html

3. GamersNexus. "TIMELINE: GPU Export Controls, NVIDIA GPU Bans, & AI GPU Black Market." 2025. https://gamersnexus.net/gpus-news/timeline-gpu-export-controls-nvidia-gpu-bans-ai-gpu-black-market

4. CSIS. "Understanding the Biden Administration's Updated Export Controls." 2025. https://www.csis.org/analysis/understanding-biden-administrations-updated-export-controls

5. SemiAnalysis. "2025 AI Diffusion Export Controls - Microsoft Regulatory Capture, Oracle Tears, Impacts Quantified." 2025. https://newsletter.semianalysis.com/p/2025-ai-diffusion-export-controls-microsoft-regulatory-capture-oracle-tears

6. ———. "2025 AI Diffusion Export Controls."

7. The Register. "The risks of export controls on AI chips." October 1, 2025. https://www.theregister.com/2025/10/01/the_risks_of_export_controls/

8. ECIPE. "H20 Back in the Chinese Market: Washington's Calculated Adjustment." 2025. https://ecipe.org/blog/nvidia-in-chinese-market/

9. Built In. "Trump Lifted the AI Chip Ban on China, Clearing Nvidia and AMD to Resume Sales: Now What?" 2025. https://builtin.com/articles/trump-lifts-ai-chip-ban-china-nvidia

10. Fortune. "Nvidia takes the gloves off with sharp words for Biden's AI export control rules." January 13, 2025. https://fortune.com/2025/01/13/nvidia-lashes-out-at-biden-administration-sweeping-last-minute-export-controls-on-ai-chips/

11. The Economy. "'Let's Absorb Middle East Oil Money' — U.S. Eases AI Chip Export Restrictions." May 2025. https://economy.ac/news/2025/05/20250549543

12. TechWire Asia. "Will US AI Chip export restrictions target Malaysia and Thailand amid China smuggling concerns?" July 2025. https://techwireasia.com/2025/07/ai-chip-curbs-malaysia-thailand/

13. IFP. "The H20 Problem: Inference, Supercomputers, and US Export Control Gaps." 2025. https://ifp.org/the-h20-problem/

14. ———. "The H20 Problem."

15. The Economy. "'Let's Absorb Middle East Oil Money.'"

16. TrendForce. "The U.S. Plans to Restrict China's GPU Access via Third Countries Like Singapore and Malaysia." December 13, 2024. https://www.trendforce.com/news/2024/12/13/news-the-u-s-plans-to-restrict-chinas-gpu-access-via-third-countries-like-singapore-and-malaysia/

17. Tom's Hardware. "Nvidia and SIA fire back at US gov's new export restrictions on AI GPUs to China." 2025. https://www.tomshardware.com/tech-industry/artificial-intelligence/nvidia-and-sia-fire-back-at-u-s-govs-new-export-restrictions-on-ai-gpus-to-china

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