Since I last wrote about China’s responses to U.S. export controls in these pages,
in February 2024, much has changed, both in terms of U.S. export
control measures and the situation on the ground in China. The relative
strength of China’s domestic semiconductor industry has also received
substantially more media attention. Teardowns of advanced semiconductors
produced by domestic foundry leader SMIC purport that China is only
three years behind global foundry leader TSMC, though these types of
predictions can be misleading.
In fact, gaining a detailed understanding of what is happening in
China’s semiconductor industry is becoming increasingly difficult.1
In May, the Chinese Semiconductor Industry Association (CSIA) issued an
ominous warning to industry insiders to avoid disclosing technical
information to media and outside consultants.2
The pattern for the semiconductor manufacturing industry in China is
following a trajectory similar to that of the high performance computer
(HPC) sector. Justified by the concern that HPCs could be used for
military applications, U.S. export controls were imposed in 2015 and
have essentially forced China’s supercomputing sector to stop publicly
revealing new systems and technological progress.3
Complicating the semiconductor industry situation in China is the
close association of U.S. controls across the sector with the
development of artificial intelligence. So far, companies developing
advanced generative AI in China have not had to conceal news about their
model development because they are operate in the consumer and
enterprise space.4
Continued U.S. pressure on the Chinese semiconductor industry will
eventually force these developers into hiding and make it more difficult
to assess progress across the AI stack in China and limit U.S.
visibility into an area of national security concern.
Understanding where Chinese companies currently stand in terms of development—from
tech conglomerate Huawei, to toolmakers, to smaller players innovating
in the development of process gases and materials for advanced
semiconductor manufacturing—is also
becoming more difficult, as the topic is now politically sensitive. The
latest round of U.S. export controls has added yet another dimension to
the issue: scores of Chinese companies, including fabs, toolmakers, and
smaller companies up and down the supply chain, are now caught up in the
broader U.S.-China competition over technology in general and
semiconductors in particular. The United States has also added critical
components such as high bandwidth memory (HBM) to its controls. The
expansion of controls reinforces what National Security Advisor Jake
Sullivan calls the “small yard and high fence” strategy focused on
containing China’s ability to develop advanced capabilities in AI.5
China’s responses, including retaliatory measures such as the
Unreliable Entity List (UEL) Anti-Foreign Sanctions Law and many other
internal policies, are now part of the equation. Beijing has also
tightened restrictions on the export of critical minerals, including
some essential for semiconductor manufacturing, namely gallium,
germanium, graphite, antimony, and soon, tungsten.6
At the same time, Chinese firms and officials are recognizing that
raw hardware manufacturing capacity for advanced semiconductors is not
the only decisive factor. As Huawei transforms from a hardware company
into a hybrid hardware-software giant, it is struggling to cultivate a
robust software development environment for its Ascend series of
advanced GPUs. Meanwhile, the firm’s HarmonyOS mobile operating system
has gained broad traction over the past year, and the firm is now
ramping up its software engineering prowess in a bid to compete
head-to-head against the likes of Nvidia in the GPU and AI datacenter
space.7
Gaining access to advanced semiconductor hardware for compute, which
means capacity for training large language models (LLMs), is now highly
complex in China.
Beijing continues to tinker with models and mechanisms of government
support for its complex, sprawling, and still very much global
technology sector. So far, it has employed a mix of government
assistance for the sector and critical pieces of supply chains, coupled
with novel financing and policy incentives, to ensure China’s access to
more advanced semiconductors over the next decade. Thus, there are both
short-term and longer-term dynamics at play in the industry and among
industrial policy planners in Beijing. The industry continues to defy
efforts to centrally plan development, so Beijing relies on
public-private partnerships, targeted funding, and greater leeway for
linchpin companies such as Huawei to drive progress in the “chokepoint
technologies” targeted by U.S. export controls and investment
restrictions. For their part, companies at the forefront of the industry
in China must continue to innovate despite severe limitations on their
access to technology, support, and spare parts, while planning for a
future largely free of U.S. and other foreign technology in their supply
chains.
The View from Beijing
Beijing’s sense of the importance of the semiconductor industry has
only grown over the past year. As Chinese officials, including President
Xi Jinping, have ramped up rhetoric critical of U.S. export controls,
Beijing has considered retaliatory measures and looked to put its
domestic semiconductor industrial complex in order.
Senior Chinese officials have gradually ramped up criticism of U.S.
controls. In March, Foreign Minister Wang Yi claimed that controls had
reached “a bewildering level of unfathomable absurdity.”8
Building on strong language first delivered in November 2023, President
Xi sharply criticized U.S. export control policy on a video call with
President Biden in April 2024. Xi argued that the restrictions
represented an effort to “suppress China’s trade and technology
development.”9
During the call, Xi apparently put the issue of U.S. export controls
nearly on par with U.S. support for Taiwan independence as a redline for
Beijing.10
Xi’s comparison of the two issues reflects how Chinese leaders see
technological control as a much more serious short-term challenge to
economic growth, while Taiwan remains a longer-term challenge. When the
United States releases a new export control package in December,
Beijing’s response has the potential to reinforce a dynamic of
tit-for-tat controls with the potential to disrupt global semiconductor
supply chains.11
As I stressed in my last article, Beijing’s primary response to U.S.
technology controls involves developing new structures to provide better
support for the domestic semiconductor industry. These tools and
policies continue to be designed, built, and fine-tuned across the
government at all levels. Developments during 2024 demonstrated a much
higher degree of involvement of domestic industry than ever before in
complex long-term industrial policy planning, in addition to high levels
of cooperation across multiple industry supply chains.
In terms of broader government policy, Beijing has also revamped its
science and technology bureaucracy with the aim of improving both the
government and private sector’s ability to innovate. In March 2023, two
critical new Party-led bodies were formed: the Central Financial
Commission (CFC) and Central Science and Technology Commission (CSTC).
Both were intended as major efforts to consolidate the Party’s authority
in vital sectors and provide tools for assisting with long-term goals
around technology development. While the CFC has been extremely active
and public in driving financial regulatory reform, the CSTC has
maintained a low profile. Party media outlets have reported little about
its mission and actions beyond issuing instructions to certain
ministries. As with other organizations and slogans, Beijing now sees
little upside to highlighting who is doing what and how when it comes to
sensitive technologies at the center of U.S.-China relations and
competition.
The CSTC is starting to have a major impact on China’s science and
technology sector and supporting ecosystems, however, by issuing new
guidance to set priorities for central funding for the development of
strategic technology sectors at the local level, according to the 2023 Notice on Management Measures for Central Guidance Funds for Local S&T Development.12
The new measures stress that funds will be prioritized for (1)
CSTC-approved major science and technology projects in need of central
financial support and (2) regional science and technology innovation
ecosystems, likely including semiconductor-focused ecosystems under
development in places such as Shanghai. These priorities suggest that
between the CFC and CSTC, Beijing is building a more focused and
centralized approach to funding for important sectors that goes beyond
basic research. Beijing appears to want to reduce what it views as
wasteful spending and overcapacity in some sectors, while making up for
its past inattention of core hard technology areas that require
longer-term planning and investment horizons, such as semiconductors.
This is a major change in thinking in Beijing.
Despite the secrecy surrounding China’s semiconductor plans, new
leaders and supporting structures have started to emerge. One major new
structure for developing policy goals for the semiconductor industry is a
Leading Small Group (LSG) under Vice Premier Ding Xuexiang. This LSG
also approves mergers and acquisitions, and coordinates with other
central bodies such as the CSTC. In June 2024, Chinese state media
revealed Ding to be the head of the CSTC, a role that gives him a lofty
perch to channel government R&D in the semiconductor industry into
private sector companies targeting strategic technological choke points.13
Information about roles, subordinations, and plans for the LSG, as well
as Ding’s role and function as CSTC chief, remain scarce, reflecting
Beijing’s increased level of sensitivity around the sector. Another
official embodying Beijing’s commitment to the semiconductor industry is
Xiangli Bin, vice chairman of China’s National Development and Reform
Commission, a powerful executive department primarily responsible for
macroeconomic management. Before his appointment to the NDRC, Xiangli
spent his career at the Chinese Academy of Sciences (CAS) leading
research into optics and precision electronics; at the NDRC, he has a
leading role on semiconductor issues, as well as a major portion of
other sectors Beijing terms “choke point technologies.”14
The View from Washington
From Washington’s perspective, tighter controls on semiconductor
manufacturing technology and GPUs are serving their purpose.
Policymakers must steadily expand the “small yard and high fence,” and
annual updates on export controls are now the norm. The U.S. Commerce
Department is planning to issue a complex set of new technology control
rules in the waning days of the Biden administration, building on the
major releases of October 2022 and October 2023.15
These rules are expected to cover new technologies critical to AI
hardware, such as HBM. The rules also likely include a substantial
rewrite of the foreign direct product rule (FDPR), giving U.S. officials
more flexibility in restricting sales of manufacturing tools from
overseas facilities of U.S. and other foreign toolmakers. Additionally,
the new rule will expand the types of tools that are restricted for
export to certain designated facilities in China....