US Department of Commerce Again Imposes Restrictions on China

The US Department of Commerce announced new semiconductor restrictions on October 7 in USA.

In addition to existing restrictions on the logic IC sector, this new update extends to the memory category. In addition to Chinese-funded enterprises, the extent of these restrictions stipulate foreign-owned production centers located in China will also need to apply for approval on a case-by-case basis in order to continue to obtain manufacturing-related equipment. In addition, the new restrictions increase the difficulty for China to obtain any chips that may be used for military purposes through imports.

According to TrendForce Corp.‘s research, the scope of this update is primarily limited to 16nm, 14nm, or more advanced proceses for logic ICs (such as FinFET or GAAFET), 18nm or more advanced processes for DRAM, and 128-layer or higher products for NAND Flash chips. 

Analysis of impact on foundry industry
In terms of foundry equipment supply, after SMIC was included on the Entity List in 2020, the US Department of Commerce targeted US equipment manufacturers who wished to export equipment used for processes below 16nm (inclusive) to Chinese fabs not included on the Entity List including HuaHong Group, etc., and even foreign-owned production centers located in China, instituting a review before export can be implemented. Therefore, most Chinese fabs are currently focusing their production expansions on processes 28nm and above. As for non-Chinese wafer foundries, only TSMC Nanjing is focused on 28nm expansion and has no plan for advanced processes.

Although Chinese fabs are actively partnering with domestic Chinese, European, and Japanese equipment manufacturers in an attempt to develop non-US centric production lines and have turned to the development of 28nm and above processes, the ban is completely stifling the possibility for China to develop and expand advanced processes 16nm and below and the expansion of processes 28nm and above is also subject to a protracted review process.

In addition, the US ban will expand the scope of its restrictions following the inclusion of high-end GPUs such as Nvidia’s A100/H100 and AMD’s MI250 in the HPC sector into the range of sanctions at the end of August. In the future, it will target US manufacturers, including HPC sector CPUs, GPUs, and AI accelerators used in datacenter, AI, and supercomputer applications, requiring review before such items can be exported to China.

In addition, foundries may no longer be able to manufacture any of the above-mentioned HPC-related chips for any Chinese IC design houses. Regardless of whether the client is a Chinese or American IC design house, most HPC-related chips are currently manufactured by TSMC with mainstream processes at the 7nm, 5nm, or certain 12nm nodes. In the future, whether the situation is American factories no longer being able to export to the Chinese market or Chinese factories being unable to initiate projects and mass produce wafer starts, it will all have a negative impact on the future purchase order status of TSMC’s 7nm and 5nm processes.

Analysis of impact on memory industry
According to the new specs announced by the US Department of Commerce, the DRAM portion of sanctions will be limited to the 18nm process (inclusive) and equipment must be reviewed by the Department before import. This move will greatly restrict or delay the sustainable development of China’s DRAM sector. CXMT possesses the largest memory market share for a Chinese company in the domestic Chinese market. Since 2Q22, the company has been committed to moving from the 19nm process into the 17nm process. Although the purchase of machinery to fulfill future needs had been accelerated before the ban, volume is still insufficient. CXMT continues to build new plants, including Phase 2 in Hefei and SMBC (SMIC Jingcheng), which is in discussion with SMIC. All of these projects will face difficulties in obtaining equipment in the future.

In addition to CXMT, the C2 plant of SK hynix’s DRAM production center in Wuxi is also affected by the restriction order. The factory accounts for approximately 13% of the world’s total DRAM production capacity and its process has evolved to 1Ynm and more advanced nodes, which means that subsequent continuous addition of equipment required for production requires approval on a case-by-case basis.

Considering geopolitics, although current market demand is sluggish and supply and demand are seriously imbalanced, the 3 major manufacturers in the DRAM market still plan to increase production capacity in their home countries in the next 10 years and continue to reduce the proportion of production in China.

In terms of NAND flash, the import of NAND production equipment into China will be further restricted in the future, especially for equipment used in the manufacture of product of 128 layers and above (inclusive), requiring prior approval before import. It is estimated that this ban will significantly impact the long-term plans of China’s YMTC to upgrade its factory campuses as well as Samsung’s Xi’an plant and Solidigm’s process migration plan in Dalian.

This ban will restrict YMTC from further expanding its customer base. At this stage, YMTC has been aggressively sending SSD products out for verification, hoping to successfully infiltrate the supply chain of non-Chinese customers in 2023. In the future, as the impact of the ban materializes, the US government will impose stricter restrictions on the development of China’s memory industry which will greatly limit non-Chinese customers’ adoption and consideration of YMTC.