The U.S. Commerce Department’s Bureau of Industry and Security (BIS) has proposed a new set of export controls on several emerging technologies, limiting the ability of China and other “adversarial nations” access to advanced computing capabilities. The new export restrictions concern fab tools that can be used to make chips with gate-all-around transistors (GAA FETs), make chips using advanced deposition equipment, equipment necessary to build quantum computers, and tools required to produce sophisticated metal allows.
“Today’s action ensures our national export controls keep step with rapidly evolving technologies and are more effective when we work in concert with international partners,” said Alan Estevez, Under Secretary for the Bureau of Industry and Security. “Aligning our controls on quantum and other advanced technologies makes it significantly more difficult for our adversaries to develop and deploy these technologies in ways that threaten our collective security.”
The document is an interim final rule (IFR), which has 60 days to be discussed and will then be imposed.
GAA transistors
The U.S. already requires makers of fab tools to apply for an export license if they plan to ship equipment that can enable Chinese entities to build logic chips on 14nm/16nm-class process technologies with FinFET transistors, DRAM chips with a half-pitch of 18nm or less, and 3D NAND with 128 layers or more. The new rules further restrict export of ‘technology’ that can enable chipmakers in China and other countries of concern to build chips with GAA transistors.
The GAA transistor-related rules are in line with those implemented on FinFET semiconductor technologies, yet the language is different. The new rules not only cover tools that are needed to produce chips featuring gate-all-around transistors, but they also cover technologies required to develop GAA chips or production nodes. This means any process, process recipe, design, or knowledge related to GAA transistors is now subject to export controls. As a result, Chinese entities now need approval from the U.S. government to develop fabrication nodes featuring GAA FETs using American technology of any kind or design chips for production nodes relying on such transistors to be made by a third party (e.g., Intel Foundry, Samsung Foundry, TSMC).
While the U.S. restricts GAA technology exports to countries posing a security risk (i.e., China, Russia, Iran, North Korea, etc.), the rules allow some flexibility for collaboration with allies through license exceptions for countries that have implemented similar technical controls. This enables U.S. companies to continue working with trusted international partners on GAA-related technologies and products. For example, Apple will not need to get an export license to make its next-generation processors at TSMC in Taiwan when the foundry adopts nanosheet gate-all-around transistors in the second half of 2025 ( it will not need an export license to work with TSMC on appropriate chips earlier as well) provided that Taiwan implements similar export rules.
ALD and ALE equipment
While the export rules imposed last year targeted specific process technologies and capabilities, they never targeted specific types of tools. The rules impose export controls on tools used for atomic layer epitaxy (ALE) and atomic layer deposition (ALD) tools — including chemical wafer deposition (CVD) and selective deposition equipment — that are widely used to make logic, memory, analog, and RF applications.
This export rule essentially ensures that even if a chipmaker from a country of concern gains access to an advanced lithography system as it already owns it or because it had managed to smuggle one or two in and even install them, it would not be able to develop a process technology that is on par with those designed in the U.S., Taiwan, or South Korea as they rely heavily on ALE and ALD processes.
Quantum computing
The new export rules place significant controls on quantum computing technologies for the first time as the U.S., China, and other countries have been making steady progress in this realm in the recent years.
The rules control quantum processors based on the number of fully functional and connected qubits. They also assess quantum computers by the error rate of Controlled-NOT (C-NOT) gates. Specifically, systems with 34 or more fully controlled qubits and meeting certain error rate limits are subject to export restrictions.
In addition, export controls are imposed on cryogenic cooling systems, which are essential for operating quantum processors. These systems, which operate at extremely low temperatures (below 200 millikelvin), are critical for maintaining performance of quantum computers. Therefore, the rules place special emphasis on cryogenic systems with a cooling power greater than or equal to 600 µW at temperatures below 0.1 K for extended periods.
The rules also control the export of technology required for development and/or production of items related to quantum computing, which includes hardware, software, and sensitive knowledge.
Exports of quantum computing technologies from the U.S. now requires a license with applications reviewed on a case-by-case basis, even if it is shipped to an allied nation. There is a presumption of denial for countries listed as high security risks, while licenses to allied nations may be approved under certain conditions. Companies who are granted an export license must provide annual reports to the BIS, detailing the release of quantum technology to foreign entities.
Additive manufacturing equipment
While additive manufacturing equipment does not necessarily point to the semiconductor world, some advanced metal alloys could be used in making chips sometime in the future. The current additive manufacturing (AM) equipment regulation is not focused around chips for now, rather on components for military devices like aircraft, missiles, and propulsion systems. For example, ceramic matrix composites (CMCs) used in gas turbine engines, aircraft, and missile structures greatly enhance performance and capabilities of the latest generation devices.
The U.S. government believes that next-generation metal AM tools with greater precision and control will significantly enhance part performance and enable advanced military capabilities that are not possible with today’s standard metal AM equipment. Therefore, the U.S. does not want any of American hardware, software, or knowledge related to advanced additive manufacturing to be exported from the U.S.
As a result, license applications to countries of high security risks will be reviewed with a presumption of denial, whereas export licenses to allied nations will be reviewed more favorably though there is no guarantee that they will be granted.
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