Semiconductor Export Controls Biweekly Brief · Oct 10–23, 2026

1. Key takeaways from the two weeks

Between Oct 10 and Oct 23, 2026, the active measures came from sanctions, procurement law and China's export catalogue, not from a new rule of the US Bureau of Industry and Security (BIS). Five conclusions explain the fortnight; each is supported in the chapter named in brackets, with measures judged against Oct 24.

1. Washington acted through sanctions and procurement, not through the export regulations. On Oct 19 the State Department and Treasury designated five entities under the Protect American Intellectual Property Act, with a bar on loans above $10,000,000 per 12 months. The Department of Homeland Security's order excluding DeepSeek from federal systems was signed on Jul 24 and published on Oct 20. The material contains no BIS rule and no Entity List addition dated Oct 10–23. [Chapter 2]

2. China moved on AI exports. On Oct 16 MOFCOM issued Announcement No. 48, a draft catalogue of 40 additions (23 AI-related, 12 solar, 5 biomedicine), and interim pre-export registration took effect the same day; comments run to Nov 15. Reports put 14 items under prohibition and 26 under restriction. [Chapter 4]

3. Congress advanced nothing in the window. The Stop Stealing our Chips Act (S. 1473) passed the Senate on May 20 and awaits the House, and the MATCH Act (H.R. 8170) remains in committee; neither is law. The $300M-plus smuggling indictment against Earthmade Computer's chief executive was announced on Oct 1–2, so it is context. [Chapter 3]

4. Compliant products fill part of the gap, with a fulfilment ceiling. Reuters reported on Oct 20 that ByteDance, Alibaba and Tencent ordered more than 3 million RTX Pro 5500 cards, a list value above $35B, while buyers may receive only 5%–10% of what they want (Nvidia has not confirmed). IDC puts Nvidia at 34% and Huawei at 28% of China's AI accelerator shipments in H1 2026. [Chapters 5, 6]

5. Dated deadlines, not new rules, set the next weeks. China's rare-earth suspension ends on Nov 10 with no extension published, and the BIS Affiliates Rule stay ends on Nov 9. ASML says China was 23% of Q3 system sales, up from 14% in Q2 and down from 42% a year earlier. [Chapters 4, 6, 7]

1.1 Measures at a glance

2. New US rules, lists and licences

Chapter 1 gave the two-week conclusions; this chapter checks each US measure for issuer, instrument and status. Washington acted through sanctions and procurement law, not the Export Administration Regulations (EAR): the material contains no BIS rule and no Entity List addition published between Oct 10 and Oct 23, 2026.

2.1 Measures table: window versus context

2.2 Sanctions and the DeepSeek order

The Oct 19 sanctions. The State Department said it was "sanctioning five entities connected to People's Republic of China national Linwei Ding" under the Protecting American Intellectual Property Act (PAIPA). Treasury's OFAC added them to its Non-SDN Menu-Based Sanctions List. Ding was convicted on Jan 29, 2026 of stealing Google trade secrets. State cites seven theft counts; Export Compliance Daily, citing DOJ, adds seven economic-espionage counts. We follow the latter, which cites DOJ directly.

The names are Shanghai Zhisuan Technology Co. Ltd., Qiji Chuangtan Beijing Investment Management Co. Ltd. (MiraclePlus), two MiraclePlus funds (Beijing Qiji Chuangtan Phase I and Phase II Venture Capital Center Limited Partnership) and Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center Limited Partnership. Zhisuan was designated for benefiting from the theft, MiraclePlus for supporting it, and the partnerships as MiraclePlus-controlled.

The effects are property blocking (importation of goods excepted), foreign-exchange and banking bans, a bar on US loans above $10 million in any 12 months, and a ban on US persons buying significant equity or debt. General License 2 permits wind-down dealings with MiraclePlus, the three partnerships and their 50%-owned entities until 12:01 a.m. ET on Jan. 19 (year not stated; upcoming). This is a sanctions measure, not a chip-export rule. On Oct 20 China's Ministry of Commerce said it would take "necessary measures" if Washington does not reverse it; Chapter 4 covers China's side.

The DeepSeek order. DHS Secretary Markwayne Mullin signed Exclusion and Removal Order #2026-01 on Jul 24, 2026, after a Federal Acquisition Security Council recommendation. The Federal Register notice appeared on Oct 20, 2026; Forkast gives the citation as 91 FR 66346, which no primary text in the material confirms. The order binds civilian agencies, except national security systems, and requires them to "Remove products provided by DeepSeek and DeepSeek-affiliated entities, and third-party products and services developed using DeepSeek implementations".

• Dates. Shattered.io describes an order made on Oct 19 with no named signatory. We follow Akin Gump, Forkast and TechTimes: Jul 24 signature, Oct 20 publication.
• Exceptions. Agencies had 60 days from issuance to ask CISA for exceptions. By our arithmetic (Jul 24 + 7 + 31 + 22 = 60 days) the window closed on Sep 22, before the public notice, as TechTimes also notes.
• Contractors. FAR 52.204-30 bars contractors from providing or using covered products absent a waiver. According to TechTimes, CISA had issued no guidance on the "developed using" test.

The binding US measures of the fortnight were a sanctions action (Oct 19) and a procurement ban (published Oct 20). Neither is a BIS export rule.

2.3 Licences and the export framework

BIS and the Entity List. Export Compliance Daily reported on Oct 13 that BIS had added no company to the Entity List "since October" (year not stated), "the longest such stretch in over a decade". The one pending BIS date is the Affiliates Rule: its published stay ends Nov 9, 2026 and the rule returns on Nov 10 unless BIS acts. The September truce extension to Jan 10, 2027 has no matching BIS rule or statement, per Wilson Sonsini and Visual Compliance (both Oct 21).

UAE and Saudi licences. On Oct 19 Export Compliance Daily quoted Nazak Nikakhtar, a Wiley lawyer and former acting BIS under secretary: "licenses, authorizations are being held" until the UAE and Saudi Arabia follow through on investment pledges. This is a former official's opinion; a BIS official did not respond. The documented background is the July 2026 UAE rule, which moved the UAE to Country Group A:5 and created supplement no. 8 to part 740. That supplement lists government agencies, 2 UAE companies (G42 and Core42) and 8 US companies as approved consignees. The material has no Saudi-specific rule.

The framework. There is still no replacement for the AI Diffusion Rule. BIS announced its rescission on May 13, 2025. A Federal Register search run on Oct 18, 2026 (thebestai.co) found no rescission document, and the eCFR of Oct 1 still carried the rule's text. agidoomsdayclock.com says the August 2026 regulatory agenda still lists it as planned. A Crowell & Moring alert (cited in) calls the rescission formal; we follow the Federal Register check. In force are the headquarters-based licence requirement (BIS guidance of May 31, 2026) and case-by-case review for chips below TPP 21,000 and 6,500 GB/s DRAM bandwidth, capped at 50% of US shipments (Jan 15, 2026 rule). The material has no lawmakers' statements on these measures; Chapter 3 covers legislation.

3. Legislation and enforcement

Chapter 2 covered what the executive branch did in the window; this chapter turns to Congress and the courts, where the material shows no bill enacted and no chamber vote dated between Oct 10 and Oct 23, 2026. What moved in the window was lobbying disclosure, not law.

3.1 Bills: where each one stands

Every bill below is a bill (not law). Each passage or committee date in the table is context (before Oct 10), not a window event.

The Stop Stealing our Chips Act is the furthest along: it needs only House action. AEI expects a Senate floor vote or a move straight to conference during the lame-duck session. Bills that die with the 119th Congress generally must be reintroduced, and the 120th Congress takes office in January 2027. Lobbying disclosures (window events). Intel and Tokyo Electron filed Q3 reports, reported by Legis1 on Oct 22 (Tokyo Electron's signed Oct 20; Intel's signing date not stated).

The arithmetic holds: 1,070,000 + 20,000 + 50,000 + 60,000 = 1,200,000, and (1,200,000 − 830,000) ÷ 830,000 ≈ 44.6%. Intel's filing covers the Chip EQUIP Act and the Chip Security Act; other filers on S. 1473 include Lenovo (United States) Inc., AI Policy Network Inc. and Entegris Inc.. Tokyo Electron lobbied on H.R. 8170 and employs a former House Foreign Affairs counsel.

3.2 The MATCH Act and servicing

H.R. 8170 would require agencies to identify sensitive equipment within 60 days and negotiate comparable controls with allies. If allies do not cooperate within 150 days, it would impose unilateral restrictions, with a five-year sunset. Legis1 names SMIC, YMTC and Huawei as targets. The Centre for a New American Security (via Tech Wire Asia) adds Hua Hong and CXMT, and says the 150 days would be given to the Netherlands and Japan, with the foreign direct product rule as the fallback. For the Dutch and Japanese response, see Chapter 4.

Servicing. Two outlets say the bill reaches installed machines. ChinaTalk's summary says Congress could restrict DUV immersion exports "and servicing", and Trending Topics says it would ban DUV sales and servicing of systems already in China. Neither quotes bill text, so treat the servicing scope as reported. ASML reported €3.3 billion of service revenue in Q3 2026, but that is a company-wide figure, not China-only.

Committee status conflict. Tech Wire Asia (Oct 15) says the House Foreign Affairs Committee ordered the bill reported on Apr 22 and that it has passed neither chamber, citing Congress.gov. Legis1 (Oct 22) says only that it was referred and "remains pending". Apr 22 is also the date Legis1 gives for H.R. 6322. We follow "in committee, no floor vote", which both sources support, and treat the Apr 22 date as unverified.

Why it is contested. ChinaTalk (Oct 2026) cites estimates that China imported about 90 immersion systems a year in 2024-25, nearly two-thirds of ASML's immersion exports, with DUV machines priced at $60-80 million. ASML's CEO Christophe Fouquet warned that overly broad restrictions would push China to build alternatives faster. SEMI favours targeted, allied controls and warns that unilateral ones could fragment supply chains, per its 2026 U.S. Policy Strategy (via Legis1). The material has no former BIS official on retaliation; ChinaTalk offers only opinion that a gradual restriction is less likely to provoke another rare-earths crisis.

Congress has produced committee votes and lobbying filings in 2026, not law: the Stop Stealing our Chips Act needs only the House, while the MATCH Act has not passed either chamber.

3.3 Enforcement: the Earthmade indictment and its red flags

The Justice Department case is context, not a window event. The indictment is an unsealed criminal charge, and a charge is an allegation. Volkov Law Group says it was unsealed on Oct 2. SpinDepth says a grand jury returned it on Sept 29 and DOJ announced it on Oct 1, and NTD says Greg Lui was arrested on Oct 1. The sources address different steps, so we use Oct 1-2 for announcement and unsealing.

According to Volkov, Lui, who runs Earthmade Computer, faces three counts: conspiracy to violate the Export Control Reform Act and the Export Administration Regulations, conspiracy to commit money laundering, and outbound smuggling. Stated maximums are 20, 20 and 10 years. SpinDepth notes that reports differ on chip models and penalties. Prosecutors say more than $300 million of servers went through Malaysia and Singapore to a buyer in Hangzhou, and that Earthmade received over $176 million from two Malaysian shipping companies between January and October 2024. Volkov says shipments continued "as recently as August of this year"; NTD describes 2023-2024 conduct, and the material does not reconcile them.

Alleged transactions (Volkov):

• 27 H100 servers for about $7.6 million, shipped from Los Angeles in January 2024;
• 512 servers quoted in April, 92 ready by June, routed via Malaysia to Hong Kong;
• 100 H100 servers worth over $22 million in July, bought through a California front company, Topmost, incorporated in February 2024.

Red flags Volkov draws from the case: a lumber-industry buyer ordering high-performance servers; a company incorporated months before a $22 million order; identity documents allegedly bought from someone else; Malaysia, Singapore and Hong Kong waypoints; a front-company shipper with a Chinese consignee; multiple freight forwarders; and a customer compliance form acknowledging licence requirements. The chips fall under ECCN 4A090.a, which needs a licence for China but not Malaysia or Singapore, so a licence-free destination is not a licence-free end user.

Singapore runs a separate fraud case over false end-user statements to server makers. Alan Wei pleaded not guilty to 11 charges on Jul 6, and police seized a bungalow worth about S$55 million. Taiwan's plan to criminalise unlicensed AI-chip shipments (Oct 16) belongs to Chapter 4.

4. Allies and China's countermeasures

Chapter 3 covered the bills and cases in Washington; this chapter turns to what governments abroad did in the same fortnight, starting with Beijing.

4.1 MOFCOM Announcement 48 of 2026: draft catalogue, interim registration in force

On Oct 16, 2026, the Ministry of Commerce (MOFCOM) and the Ministry of Science and Technology (MOST) issued Announcement No. 48 of 2026. It proposes adding 40 technologies to the Catalogue of Technologies Prohibited and Restricted from Export, with comments open Oct 16 to Nov 15, 2026, under the Foreign Trade Law and the technology import and export regulations. The material has no MOFCOM page text, so the account below rests on secondary reports of the notice (ChinaTalk, Dealroom, Pasquale Pillitteri, DEV Community, CellCog). They agree on dates and counts.

Announcement 48 has two layers. The 40-item catalogue is a draft until comments close on Nov 15 and a final version is issued (no date announced). The registration duty is already in effect as an interim measure from Oct 16 until the revised catalogue takes effect, and it covers exports begun but not finished.

What is listed. The 40 items split into 23 AI, 12 solar and 5 biomedicine. 14 are prohibitions (J codes) and 26 are licence-restricted (X codes). The ministry page does not itself show the split; Global Times does, and we follow that. The AI items cover large models, agents, computing clusters and information processing.

What is prohibited. Reports name the core technology of large models trained on sensitive national data, and of agents built for defence, critical information infrastructure or core government systems. The spokesperson's example is AI-driven malicious-code generation and mutation. Restricted examples are AI-assisted vulnerability discovery, AI-chip design with 2.5D/3D integration, 3D flash memory and speech recognition.

Thresholds sit in Attachment 1, which the notice page does not render, so these figures come from news. Bloomberg and AP report restricted models at 2 trillion parameters or more, or a global top-10 rank. CellCog and The Decoder add 10^26 training FLOPs. Reports differ on the "core/important data" line: Tech Times says ban, CellCog says restriction. Kimi K3 and Qwen3.8-Max are reported to exceed the size line, but the draft names no model.

What registration means. An exporter must register before it (1) assigns ownership abroad, (2) licenses the technology abroad, (3) changes the owner or actual controller to a foreign entity, or (4) does anything else MOFCOM later specifies. The form asks for parties, destination, technology, intended use and estimated value. ChinaTalk reads trigger 3 as codifying the Manus case, and the whole regime as data-gathering before licensing.

What stays outside. According to MOFCOM's spokesperson, API, app, web, SaaS and lightweight on-device access is not a technology export, and weights already public through open source or papers are out of scope. A restricted model installed on servers abroad is in scope, though automatic licensing may apply to open-sourcing and the company's own overseas cloud. MOFCOM says no country is targeted.

4.2 Rare earths and the Washington summit

The summit is context, not a window event: Sep 23–25 per Heritage, Sep 24–26 per Wilson Sonsini. Wilson Sonsini (Oct 21) lists three trade outcomes: the Board of Trade and Board of Investment, a two-month extension of the Busan truce from Nov 10, 2026 to Jan 10, 2027, and a "US$30 billion for US$30 billion" tariff framework. Neither side scaled back national-security controls.

The rare-earth deadline is less settled than the truce. China's suspension of its October 2025 controls (Announcement No. 70, Nov 7, 2025) runs to Nov 10, 2026, 17 days away. MOFCOM's Sep 28 statement on the Jan 10 extension did not mention rare earths, and on Oct 21 Peacock Tariff Consulting found no published instrument extending any of the four Nov 10 expiries. Wilson Sonsini counts the suspension as extended, while noting that BIS has not confirmed the matching Affiliates Rule suspension. We follow the published instruments: Nov 10 is the only dated expiry, and an extension is unconfirmed.

If it lapses, the 0.1% foreign-content rule (Announcement No. 61) returns. The April 2025 licences for seven medium and heavy rare earths were never suspended and remain in effect. September rare-earth exports were 4,269.8 t (+6.7% year on year), but January–September was 43,711 t (−9.6%).

4.3 Allies: Netherlands, Japan, ASML and Taiwan

Netherlands and Japan. The material holds no new Dutch or Japanese government measure dated in the window. Context only: the Dutch government does not license EUV exports to China, and the MATCH Act (a bill, not law; see Chapter 3) would give the Netherlands and Japan 150 days to align.

ASML (company results, Oct 14). Q3 net sales were a record €11.7 billion (+55%). ASML kept its view that China is about 20% of 2026 net sales, and CEO Christophe Fouquet said demand there "remains very strong" for 2027.

The headline "doubling" is quarter on quarter: 23% × €8.4bn ≈ €1.9bn against 14% × €6.6bn ≈ €0.9bn. Year on year it fell: 42% × €5,553.8m ≈ €2.33bn against 23% × €8,373.2m ≈ €1.93bn, about 17% lower (our calculation from). TechPowerUp reports CXMT and YMTC stockpiling DUV tools for three years; that is a report, not an ASML statement.

Taiwan (announced plan, not in effect). Economics Minister Kung Ming-hsin told Bloomberg that Taiwan will add advanced semiconductors and AI servers to its controlled list, making unauthorised shipments to China a crime under the Foreign Trade Act. Bloomberg published on Oct 16; Taiwan News calls it a "Monday interview". Kung tied it to the Taiwan–US Agreement on Reciprocal Trade. Reports say it needs a legal amendment, with no start date, penalties or product list given. Current controls rely on a company blacklist that added Huawei and SMIC in mid-2025. An August 2026 case against nine people over 130 servers used breach-of-trust and forgery charges, which shows the gap.

5. Affected companies and products

Chapter 4 set out China's countermeasures and the allied measures; this chapter asks which companies carry the exposure. The answer is mostly reports and estimates, not filings.

5.1 Company exposure at a glance

The two headline Nvidia numbers are not company figures. The $35 billion RTX Pro 5500 order is a list-price total from unnamed sources that Nvidia has not confirmed, and the 34% China share is an IDC estimate seen by Reuters.

5.2 Nvidia, compliant products and the Chinese challengers

Orders (reported). Reuters reported on Oct 20, 2026 that ByteDance, Alibaba and Tencent ordered over 3 million RTX Pro 5500 cards at about $11,400 each, and that total Chinese orders exceed 6 million. It is a workstation GPU bought mainly for inference, below the B300 (barred) and the H200 (licensed case by case). The $35 billion is a sticker price: 3 million × $11,400 = $34.2 billion, so "over $35 billion" implies about 3.07 million cards.

Fulfilment caveat. Nvidia told customers and partners it cannot guarantee it can fill the orders. One source said buyers may get only 5%–10% of what they requested, another that Nvidia can make no more than 3 million cards globally in 2027. On 3 million ordered, 5%–10% is 150,000–300,000 cards, about $1.7–3.4 billion at list price (our arithmetic). Early samples are expected in December 2026 and commercial shipments in Q1 2027. Nvidia has not confirmed the order. Shenzhen-listed Tansun Technology separately disclosed on Oct 13 a deal for 20,000 of the cards from an unidentified seller.

Nvidia's own statements are narrower. A spokesperson said Chinese workstation-chip makers had seen "unprecedented growth since 2022" and called US controls "outdated". Guidance of $108.0 billion ± 2% for the current quarter excludes China data-center compute revenue, with results due Nov 18 (Yahoo Finance's reading of the guidance). In the quarter ended July 26, H200 sales to China were under 1% of the $89 billion data-center revenue, so below $0.89 billion.

Share (analyst estimate). IDC, seen by Reuters on Oct 13, counts H1 2026 unit shipments of data-center AI accelerators in China:

Check: 678,000 ÷ 2.008M = 33.8%. IDC did not say which Nvidia products are counted or whether smuggled B200/B300 parts are included. It expects 2026 shipments up 19% but GPUs down 9%. Other estimates differ: an aggregator cites IDC at 55% for Nvidia in 2025, and a Bernstein 50%/8% split is unconfirmed. We follow IDC H1 2026 as the only set with published units. Huawei's Eric Xu said Ascend "has surpassed Nvidia" but gave no data.

DeepSeek (reported). The Information reported that DeepSeek plans to start training on Ascend 950DT as soon as end-2026, and that Huawei will prioritise it for most 960DT chips due in Q1 2027. Training still leans on Nvidia hardware.

5.3 Equipment makers, Korean memory fabs and Intel

ASML (company results, Oct 14). Q3 2026 sales were €11.7 billion (€11,662 million vs €7,516 million, +55.2%), and ASML said planned 2027–2028 supply "will not fully meet the demand of our customers". TechPowerUp reports China at 23% of system sales, against 14% in Q2, behind Taiwan 32% and South Korea 31%; StockTitan's calculation puts China at 42% a year earlier. These are different baselines, not a conflict. Dutch measures are in Chapter 4.

Tokyo Electron and Intel (filings). Tokyo Electron's in-house Q3 lobbying report, signed Oct 20, lists $110,000 (Q2: $100,000) and cites the MATCH Act, H.R. 8170, pending in committee and not law. Intel's Q3 lobbying rose 44.6% to $1.2 million and covers the Stop Stealing our Chips Act, passed by the Senate on May 20 and awaiting House action. See Chapter 3.

Samsung and SK hynix (reported, Oct 21). Reuters reported that Samsung is converting Xi'an to 286-layer V9 NAND, targeting 5,000 wafers a month in December 2026 and 40,000 by December 2027, and that SK hynix is moving Dalian from 192 to 240-plus layers. Both companies confirmed upgrades are under way in consultation with the US government and said they are not adding capacity; Reuters could not establish the extent of the equipment licences. Context: BIS said in August 2025 it would license existing operations but not expansion or upgrades, and both received annual licences for 2026 on Dec 30, 2025. SK hynix's 2027 Dalian authorisation has reportedly not been issued. Reuters gives YMTC 38.5% of China NAND in Q2 2026, Samsung 33.5% and SK hynix 17%, with no analyst firm named.

Judgement. Compliant products now set the China revenue ceiling for US firms, and supply, not demand, is the limit. The Korean fabs depend on a licence that must be renewed each year.

6. Supply-chain adjustments

Chapter 5 sized each company's exposure; this chapter records how buyers, suppliers and governments adjusted around the controls. Only dated, sourced moves are listed, and anything before Oct 10, 2026 is marked context.

6.1 Adjustment table

Analysis: every adjustment works at the edge of the controls, not outside them. Compliant GPUs and Huawei's Ascend are both short, so the controls are absorbed through scarcity and price rather than avoided.

6.2 Workarounds and limits

Workstation GPUs. The FT expects about 3.5 million domestic AI chips against demand "far exceeding" 5 million, a gap of at least 5.0 − 3.5 = 1.5 million. Compliant Nvidia cards serve "simpler AI workloads" such as prefill, since they cannot match Huawei's Ascend 910C, and buyers still prefer CUDA to CANN. iSoftStone reportedly secured 8,000 RTX PRO 6000D cards worth about 560 million yuan (US$86.9 million), or 560M ÷ 8,000 = 70,000 yuan (about US$10,900) a card.

Price and fulfilment limit the workaround. The RTX 5090 lists at $1,999 but sells at three resellers for at least $7,199, 3.6 times list. Reuters reports over 6M RTX Pro 5500 orders against up to 3M cards built in 2027, so fulfilment cannot exceed 50%, yet Nvidia reportedly told partners 5–10%; the material does not reconcile the two.

Domestic substitution. Huawei is also capacity-bound. Rotating chairman Xu Zhijun said on Sept 17 (context): "We have not secured production capacity sufficient to meet demand within China". Per 36Kr, SMIC yield and HBM supply are the limits, and spot premiums once passed 30%. Its 910C figures conflict: 812,000 units shipped in 2025, yet a Bloomberg-reported 2026 plan of about 600,000 is called "almost doubling"; treat the plan as unreliable.

Remote access and compliance. The Institute for Progress (IFP, Oct 19) estimates China's AI compute at 4.6M H100-equivalents at end-2026 and 8.8M at end-2027 (1.9 times), with about half of the restrictable part in overseas data centres reached remotely (estimate, advocacy). For server shipments the material holds no dated company change. Analysis: Volkov Law Group (Oct 11) says screening that stops at the first consignee is "blind to transshipment"; that is advice, not an adjustment. The regulator's side is context: a BIS final rule of Jan 15, 2026 put H200 and MI325X sales to China on case-by-case review with a 25% tariff, 50% volume cap, third-party testing and KYC, according to Silicon Analysts.

Tools. Chinese toolmakers averaged 36% revenue growth in H1 2026 (The Information Network, via 24/7 Wall St.). ASML expects China at about 20% of 2026 net sales. The material has no China revenue shares for Applied Materials, Lam or KLA. ASML's Installed Base Management (servicing and upgrades) earned €3,289m in Q3 against €2,762m in Q2, +19%, with no country split. The MATCH Act, a bill and not law, would also reach servicing (Chapter 3).

6.3 Critical minerals and managed access

EU managed access (context, Oct 9). The Oct 8–9 EU-China consultations produced a "green channel" for rare-earth and permanent-magnet licences. China's readout is silent on rare earths, and Bruegel (analysis) says leaving this to China's discretion guarantees no supply. Three magnet makers (JL MAG, Beijing Zhong Ke San Huan, Yunsheng) have held year-long general licences since December 2025, excluding defence users (context).

Deadlines. The pause on the October 2025 controls (Notices 55–58, 61, 62 of 2025) lapses on Nov 10, 2026; the April 2025 licences (Announcement No. 18) were never suspended. MOFCOM said on Sept 28 that US trade arrangements run to Jan 10, 2027, without mentioning rare earths. The SPF analysis reads the pause as extended to Jan 10, 2027. We follow ref_61 and ref_106, which show no published extension. A separate germanium and gallium suspension (MOFCOM No. 72 of 2025) runs to Nov 27, 2026, with no extension published. See Chapter 4.

Flows and buyer response. September customs data (reported Oct 20) show gallium exports of 2,030 kg, +480% on August but below 5,000 kg a year earlier, and germanium of 573 kg, −79% from 2,769 kg in August. Germany received no gallium for a second month. According to TechTimes, non-Chinese concentrates trade at estimated 15–25% premiums. The SIA found only 68% of US chip equipment and materials is made in the US, Europe or Japan, against 95% by supplier headquarters, and urged stockpiles (date not stated). Analysis: stockpiling is advised more than documented.

7. What the fortnight adds up to, and what comes next

Chapters 2–6 covered US measures, legislation, China and the allies, affected companies and supply-chain adjustments. This chapter reads them together and adds a dated watch-list. It uses only facts from earlier chapters.

7.1 What changed, and what did not

The US lever this fortnight was sanctions and procurement. The five PAIPA designations took effect on Oct 19 and the DeepSeek order was published on Oct 20, but the material shows no BIS rule or Entity List addition dated Oct 10–23. Reports that licences for the UAE and Saudi Arabia are being held until investments follow through come from a former official, not from BIS.

China's lever is now AI itself. Announcement No. 48 lists 40 additions, of which 23 are AI-related, and reports put 14 under prohibition and 26 under restriction; the catalogue is a draft but interim pre-export registration has applied since Oct 16. The thresholds for restricted models come from news reports, not from the rendered attachment, so treat them as reported.

Legislation is a pipeline, not law. S. 1473 passed the Senate on May 20 and awaits the House; the MATCH Act would give the Netherlands and Japan 150 days to align and remains in committee. Intel's Q3 lobbying rose to $1.2M from $830,000 in Q2, a 44.6% increase.

Companies are adapting around the controls. The reported RTX Pro 5500 orders exceed 3 million cards at about $11,400 (3M × $11,400 = $34.2B), but Nvidia is reported to be able to build up to about 3 million in 2027 against more than 6 million of Chinese orders, so the reported fulfilment is 5%–10%. IDC's H1 2026 figures show Nvidia at 678,000 units (34%) and Huawei at 572,000 (28%) of 2.008 million. ASML's China share of system sales was 23% in Q3 2026 against 14% in Q2 and 42% in Q3 2025.

Critical minerals set the near-term clock. China's rare-earth suspension ends on Nov 10 with no published extension, and the germanium and gallium suspension runs to Nov 27. Sources disagree on whether the Busan truce extension to Jan 10, 2027 also covers rare earths, so the safe reading is that Nov 10 is the only dated expiry.

7.2 What it means by reader

Treat bills and drafts as pending, count only effective measures as changes, and track the November deadlines.

7.3 Key dates

Dates already past on Oct 24, 2026 are marked "In effect".

8. References

This document draws on the following 76 sources, listed in the order they are first cited.

1. Imposing Sanctions to Protect Americans from Intellectual Property Theft - United States Department of State — state.gov
2. Protecting American Intellectual Property Act of 2022 (PAIPA) Designations; Issuance of Associated General Licenses | Office of Foreign Assets Control — ofac.treasury.gov
3. DHS Orders Exclusion and Removal of DeepSeek Products From Federal Civilian Agency Systems — akingump.com
4. Analyst: No BIS Update to Advanced Tech License Exception Causing Uneven Treatment for Allies — exportcompliancedaily.com
5. China AI Export Controls: 2T Models and Agents Listed | CellCog — cellcog.ai
6. China drafts export curbs on 40 AI, solar and biotech technologies | Dealroom News — dealroom.co
7. MOFCOM’s New AI Rules — chinatalk.media
8. Intel Lobbying Rises as Senate Advances Chip Export Controls | Legis1 — legis1.com
9. Tokyo Electron Increases Lobbying on Semiconductor Export Controls | Legis1 — legis1.com
10. A $300 Million Chip-Smuggling Indictment Is a Case Study in Every Red Flag Export Compliance Teams Are Told to Watch - Corruption, Crime & Compliance — blog.volkovlaw.com
11. ByteDance, Alibaba and Tencent order over $35B in Nvidia chips amid US curbs: report — invezz.com
12. China’s tech giants drop $35 billion on export-compliant Nvidia RTX Pro 5500 workstation GPU orders to power AI ambitions, according to reports — ByteDance, Alibaba and Tencent order 3 million cards despite warnings that only 10% of orders are fulfillable | Tom's Hardware — tomshardware.com
13. Nvidia’s China AI chip market share falls to 34% as Huawei gains ground: IDC — TradingView News — tradingview.com
14. Nov 10 Cliff - Peacock Tariff Consulting — peacocktariffconsulting.com
15. The BIS 50% Rule and the U.S.–China Trade Truce Extension: Why Compliance Teams Are Acting Now | Visual Compliance: International Trade Compliance Software — visualcompliance.com
16. ASML Shipments to China Surge to 23% of System Sales in Q3 2026 | TechPowerUp — techpowerup.com
17. ASML Q3 2026 Earnings: Orders, 2027 Supply and China — stocktitan.net
18. DHS Ordered Every Federal Agency to Purge DeepSeek. The Exclusion Follows the Model Into Anything Built On It. – Forkast — forkast.news
19. AI chip export controls — what the US rules restrict — themodelpress.com
20. Global AI Governance · Volume VIII · The AI / SI Encyclopedia — thebestai.co
21. US Sanctions Five Chinese Entities Over Google Trade-Secret Theft — exportcompliancedaily.com
22. China opposes US sanctions over trade secret allegations - Chinadaily.com.cn — global.chinadaily.com.cn
23. DHS Bans DeepSeek on Federal Systems Under 2018 Law — shattered.io
24. DHS Filed DeepSeek Ban 28 Days After Agencies Lost Right to Request Exceptions — techtimes.com
25. U.S.-China Washington Summit 2026: Key Outcomes and Unfinished Business | Wilson Sonsini — wsgr.com
26. Former BIS Official: Chip Licenses Being Held Until UAE, Saudis Follow Through on Investments — exportcompliancedaily.com
27. AI Chip Export Controls and Compute Overhang in 2026 — agidoomsdayclock.com
28. Important Asia Provisions in the House and Senate 2027 National Defense Authorization Act | American Enterprise Institute - AEI — aei.org
29. IBM Lobbying Falls Amid AI Copyright and Tax Legislation Debate | Legis1 — legis1.com
30. Policy Briefs - Everything Policy — everythingpolicy.org
31. ASML China sales double in Q3 as share falls on a year ago — techwireasia.com
32. The Lithography Lever — chinatalk.media
33. ASML Can’t Build Machines Fast Enough for the A.I. Boom | Trending Topics — trendingtopics.eu
34. AI Chip Smuggling Trail Runs Through Malaysia and Singapore — spindepth.com
35. US Prosecutor Warns Chinese Espionage Is ‘Extremely Pervasive,’ Citing Recent Cases | NTD — ntd.com
36. Smuggling Nvidia Chips Into China Is About to Become a Crime in Taiwan - 24/7 Wall St. — 247wallst.com
37. China's AI Export Draft Spares API Calls and Public Weights. Overseas Deploys Aren't - DEV Community — dev.to
38. China announces export controls on 23 AI technologies — pasqualepillitteri.it
39. China’s New AI Export Controls Apply Now if You Licensed or Deployed Covered Chinese Models — techtimes.com
40. Time Bought, Leverage Preserved: Outcomes of the Trump–Xi Summit in Washington | The Heritage Foundation — heritage.org
41. Rare Earth Export Pause: 10 Nov Deadline and Key Outcomes — rare-earth-mining.com
42. China's rare earth leverage has an expiration date: November 10. Here's what Beijing is deciding — fxstreet.com
43. Taiwan to Curb AI Chip Exports to China as Part of US Trade Deal — news.bloomberglaw.com
44. Taiwan to impose strict controls on AI chip exports to China | Taiwan News | Oct. 16, 2026 20:16 — taiwannews.com.tw
45. Smuggling Nvidia Chips Into China Is About to Become a Crime in Taiwan — finance.yahoo.com
46. ByteDance, Alibaba and Tencent Just Ordered $35 Billion of Nvidia Chips — finance.yahoo.com
47. DeepSeek teams up with Huawei to challenge Nvidia — finance.yahoo.com
48. Samsung and SK hynix China NAND Upgrades: More Bits, Better Margins? – AHNIM STUDIO — ahnimstudio.com
49. Samsung, SK Hynix Push China NAND Toward 286 Layers as BIS Stays Silent on License Approval — techtimes.com
50. ByteDance, Alibaba, and Tencent order NVIDIA RTX PRO 5500 chips worth over $35 billion — tweaktown.com
51. China's $35B Nvidia GPU Order Tests Export Limits — shattered.io
52. ByteDance, Alibaba and Tencent order $35bn in Nvidia cards — Taipei Times | UA.NEWS — ua.news
53. Who decides what constitutes dangerous artificial intelligence: the state or Nvidia? — tomorrowsaffairs.com
54. Nvidia’s share of China AI chip market falls to 34% as Huawei gains ground - The Economic Times — m.economictimes.com
55. Nvidia China Market Share Drops to 34% as Huawei Hits 28% — tech-insider.org
56. DeepSeek to pre-train on Huawei Ascend 950DT by end of 2026 | AI Weekly — aiweekly.co
57. Samsung, SK Hynix Upgrade China Fabs to More Advanced NAND | AI Weekly — aiweekly.co
58. SK hynix needs a Trump 2027 deal to expand its Dalian NAND fab - Asia Times — asiatimes.com
59. Chinese AI companies buy 1 million Nvidia gaming and workstation GPUs in a single year, report claims — export control-compliant chips flood the market to bridge gap in compute demand | Tom's Hardware — tomshardware.com
60. "Supply Falls Short Despite Acceleration in Localization" Continued Reliance on NVIDIA Amidst China's AI Chip Supply Shortage, Including Smuggling and Use of Overseas Cloud Services | The Economy — economy.ac
61. Nvidia secures $35B in orders for new export-compliant GPU from Chinese tech giants: report — TradingView News — tradingview.com
62. 6% Gap Between NVIDIA & Huawei: China's AI Chip Market Competitive Landscape Shifts — eu.36kr.com
63. 10 Semiconductor Equipment Stories That Matter in 2026 — nuttycld.substack.com
64. China Briefing 15 October 2026: EU-China agreement | ‘New quality productive forces’ | Protecting China’s mangroves  - Carbon Brief — carbonbrief.org
65. A first step, but no real rebalancing in the European Union’s trade deal with China — bruegel.org
66. China / Desk — 16 Oct 2026 — cyberverso.net
67. Semiconductor Hegemony Loses Ground to Rising China — chosun.com
68. How to Increase America’s AI Lead Over China | IFP — ifp.org
69. The Framework Is the Policy: How the US Export Control… — siliconanalysts.com
70. Applied Materials Faces Market Share Test as Global Chip Equipment Spending Surges 23% — finance.yahoo.com
71. ASML Q3 2026 Results: Record €11.7bn Sales, Supply Short to 2028 — globalbrandsmagazine.com
72. Why China’s Rare-Earth Leverage Does Not Wear Out | List of Articles | International Information Network Analysis | SPF — spf.org
73. China Germanium Export Controls November 2026 Deadline — rareearthexchanges.com
74. China’s Gallium Exports Rebound as Germanium Shipments Slump - RAWMATERIALS.net — rawmaterials.net
75. China's October Industrial Doctrine Formalizes Rare Earth Leverage: EU Secured Managed Access — techtimes.com
76. SIA's Latest Assessment: Deep Risks in the Chip Supply Chain Have Been Severely Underestimated — BigGo Finance — finance.biggo.com