Regulation ChangeLiveLive Regulation
BIS revises license review policy for advanced computing exports to China
EAR USBureau of Industry and Security (BIS), U.S. Department of CommerceUS, China
Announced
Jan 15, 2026
Effective
Jan 15, 2026
Implementation
Jan 15, 2026
Description
BIS issued a final rule revising the license review policy for advanced computing commodities exported to China. The policy changes from a presumption of denial to case-by-case review for certain advanced semiconductors including Nvidia H200 and AMD MI325X. Approval requires that exports must not reduce global semiconductor capacity available to U.S. customers, Chinese purchasers must adopt export compliance procedures including customer screening, and products must undergo independent third-party testing in the U.S. for performance and security verification. This follows a December 8, 2025 Presidential announcement allowing H200 and similar products to approved China customers.
Sources
Key Findings
BIS revises license review policy for advanced computing exports to China
o be reviewed on a case-by-case basis for purposes of § 744.23. This final rule also includes a change that removes “or” at the end of paragraph (d)(3)(ii) and revises newly redesignated par