由 caicai8478 I. Current situation of international semiconductor technology export restrictions
In recent years, the global semiconductor industry has faced an increasingly complex international trade environment, and Western countries led by the United States have continuously strengthened technology export controls on China:
The US BIS frequently updates the entity list to restrict the export of advanced process equipment, EDA tools, etc. to China
Semiconductor equipment powers such as Japan and the Netherlands have joined the export control alliance
“Chip 4” and other mechanisms attempt to reconstruct the global semiconductor supply chain
II. Main challenges of international compliance requirements
- Expansion of technology control scope
From traditional military use to civilian fields (such as AI, supercomputing, etc.)
Control standards have expanded from specific parameters to a broader range of technologies
- Increased risk of long-arm jurisdiction
The United States uses the “minimum content principle” to implement extraterritorial jurisdiction
Increased risk of transit trade in third countries
- Substantial increase in compliance costs
Increased supply chain review and due diligence requirements
Technology classification and export license application process have become more complicated
III. Response strategies of Chinese companies
- Establish a sound compliance management system
Establish a full-time export compliance department and deploy professionals familiar with EAR/ITAR
Implement full-process compliance control: R&D, procurement, production, and sales
Establish a list of “red line technologies” and regularly update risk assessments - Diversified supply chain layout
Establish a database of alternative suppliers to reduce reliance on a single source
Strengthen strategic cooperation with domestic equipment/material manufacturers
Consider setting up R&D centers or production bases in unregulated areas - Technological innovation and independent control
Increase investment in the R&D of mature process characteristics
Promote the process of domestic substitution of semiconductor equipment and materials
Participate in industry alliances to jointly break through key “bottleneck” technologies - International compliance operation
Establish a global compliance audit mechanism and regularly inspect overseas subsidiaries
Employ professional law firms for trade compliance consulting
Participate in the formulation of international standards and strive for technical discourse power
IV. Typical case reference
A memory chip company: successfully avoided multiple potential illegal transactions by establishing a “three-stage screening” mechanism (product screening, customer screening, and use screening)
A semiconductor equipment company: established a research and development center in the Netherlands to legally obtain some restricted technologies while maintaining compliance operations
An IC design company: adopt a “dual-track” technology route to develop both regulated and unregulated versions of product lines
V. Future Outlook
As technological competition intensifies, export controls will become the norm. Chinese companies should:
Integrate compliance requirements into long-term strategies rather than short-term responses
Balance the relationship between technological autonomy and international cooperation
Actively participate in the formulation of international rules and strive for a fairer competitive environment
The global nature of the semiconductor industry will not change, but the rules of the game are being reconstructed. Only by building compliance capabilities into core competitiveness can Chinese companies achieve sustainable development on the international stage.