US export controls on AI accelerators bound for China
A bi-temporal extract. Every assertion carries the interval over which it held and the record it was drawn from. Superseded states are retained, not overwritten, so the sequence of policy reversals is legible rather than flattened into a current position.
Nodes
| ID | POLE+O class | Label | Identifier |
|---|---|---|---|
| n1 | Object / Organization | NVIDIA Corporation | NASDAQ: NVDA, Q182477 |
| n2 | Object / Hardware | NVIDIA H20 accelerator | obj:nvda-h20 |
| n3 | Object / Hardware | NVIDIA H200 accelerator | obj:nvda-h200 |
| n4 | Location | China, incl. Hong Kong and Macau | Q148 |
| n5 | Location / Control group | D:5 country group | EAR Supp. No. 1 to Part 740 |
| n6 | Object / Government body | Bureau of Industry and Security | BIS, US Dept of Commerce |
| n7 | Event | Licence requirement imposed | ev:2025-04-09 |
| n8 | Event | Revised BIS licence review policy | ev:2026-01-16 |
Edges with temporal validity
| Subject | Predicate | Object | valid_from | valid_to | Src |
|---|---|---|---|---|---|
| n2 H20 | exportable_without_licence_to | n4 China | 2024-03 | 2025-04-09 | [1] |
| n2 H20 | requires_export_licence_for | n4 China | 2025-04-09 | open | [1] |
| n2 H20 | requires_export_licence_for | n5 D:5 group | 2025-04-09 | open | [1] |
| n6 BIS | issues_licences_for | n2 H20 into n4 | 2025-08 | open | [2] |
| n6 BIS | reviews_case_by_case | n3 H200 into n4 | 2026-01-16 | open | [3] |
| n1 NVIDIA | supplies_market | n4 China | 2024-03 | 2025-04-09 | [1] |
| n1 NVIDIA | supplies_market_under_licence | n4 China | 2025-08 | open | [2] |
Superseded states
| Attribute | Value | valid_from | valid_to | Status | Src |
|---|---|---|---|---|---|
| H20 export status, China | No licence required | 2024-03 | 2025-04-09 | superseded | [1] |
| H20 export status, China | Licence required, none issued | 2025-04-09 | 2025-08 | superseded | [1] |
| H20 export status, China | Licence required, licences issued | 2025-08 | open | current | [2] |
| Stated duration of requirement | "Indefinite future" | 2025-04-14 | 2025-08 | contradicted | [1] |
Recorded contradictions
C1. Stated duration against observed practice
On 14 April 2025 the US government advised NVIDIA that the licence requirement applied "for the indefinite future". By August 2025 the Commerce Department was issuing licences for the same product into the same market. Both assertions are retained. A current-state model would hold only the second and lose the reversal.
C2. Approved licence volume against realised shipments
Following the January 2026 policy revision, a substantial volume of licences was approved for higher-tier accelerators into China. In July 2026 a Commerce Department export-controls official told Congress that shipments had been "very few". Licence approval and licence utilisation are separate edges with separate validity, and conflating them overstates realised market access.
C3. Control scope against commercial substitution
The control is written against named product tiers rather than against capability. Each tightening has been followed by a redefinition of what the controlled tier is, which means the same edge label carries a different technical meaning at different points on the timeline. Comparisons across periods require the tier definition in force at each date, not the current one.
Sources
- NVIDIA Corporation, Form 8-K, filed 9 April 2025. sec.gov
- Reporting on Commerce Department issuance of H20 export licences, August 2025. Primary record pending.
- Bureau of Industry and Security, revised licence review policy for semiconductors exported to China. bis.gov
Method and limits
Assertions carry the precision of their source. Where a record gives a month without a day, the interval is recorded to the month. Contradictions are recorded where two sourced assertions cannot both hold; they are not resolved in favour of either. The extract displays what the records state and does not infer relationships that no record supports. Where a primary record is not yet linked, the entry is marked pending rather than presented as verified.