Scrutica
Regulatory Landscape as of April 2026
The Biden-era AI Diffusion Rule (three-tier country framework) was rescinded May 2025. No formal replacement exists. Core Oct 2022 and Oct 2023 rules remain in force. H200 and MI325X shifted to case-by-case review (Jan 2026). Blackwell-class chips remain fully restricted for China.
The current export control landscape is in transition. The 2025 AI Diffusion Rule was rescinded before taking effect, and no replacement has been issued. The foundational October 2022 and October 2023 restrictions remain operative, meaning advanced AI chips (H100-class and above) cannot be shipped to China. Newer chips (H200, MI325X) require individual government review since January 2026; the most advanced Blackwell-class chips remain fully restricted for China.
Sources: Federal Register 87 FR 62186, 88 FR 73458; BIS press releases; CRS R48642
Sources: U.S. Bureau of Industry and Security regulatory publications, Congressional Research Service analysis, manufacturer specifications
Full EAR classification (ECCN 3A090, 4A090) with specific performance thresholds (TOPS, bandwidth, interconnect parameters). License exception applicability per chip-destination pair.
Each AI chip is classified by its computing power. Above certain thresholds set by the US government, sales to certain countries require government approval or are prohibited entirely.
Chip specifications from manufacturer datasheets (NVIDIA, AMD) where available. Estimated values marked with ~ prefix. Regulatory thresholds from Federal Register publications. Country access profiles derived mechanically from applicable rules. Huawei Ascend 910B specs are from secondary sources (CSET Georgetown, industry reports); no official Huawei datasheet is publicly available. B30A specifications are unverified industry estimates (TrendForce, Aug 2025).