US government announces new rules for exporting NVIDIA and AMD AI chips to China, allowing export of H200 and MI325X chips with restrictions

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) published new rules regarding exports of advanced computing semiconductors to China and Macau on January 15, 2026. The rules relax the 'presumption of denial' policy previously applied to certain semiconductor exports to a 'case-by-case review' policy where certain conditions are met.

Federal Register :: Public Inspection: Revision to License Review Policy for Advanced Computing Commodities
https://www.federalregister.gov/public-inspection/2026-00789/revision-to-license-review-policy-for-advanced-computing-commodities

US posts official H200 and MI325X AI GPU export rules to China, but with plenty of caveats — a string of requirments greatly limits the total number of GPUs that can be shipped to China | Tom's Hardware
https://www.tomshardware.com/tech-industry/artificial-intelligence/us-posts-official-h200-and-mi325x-ai-gpu-export-rules-to-china-but-with-plenty-of-caveats-a-string-of-requirments-greatly-limits-the-total-number-of-gpus-that-can-be-shipped-to-china

The main products affected include NVIDIA's H200 and AMD's Instinct MI325X, as well as chips with similar or lower performance.

To qualify for this mitigation, a product must have a total processing performance (TPP) score of less than 21,000 points and a total DRAM bandwidth of less than 6,500 GB/s. Specifically, the NVIDIA H200 has a TPP score of 15,832 and a memory bandwidth of approximately 4,800 GB/s, while the AMD MI325X has a TPP score of 20,800 and a memory bandwidth of approximately 6,000 GB/s, both of which are below the thresholds set by this mitigation.

However, in order to obtain this export permit, not only must the product be below the standard value, but it must also meet several other very strict requirements.

First, they must prove that US domestic demand is being fully met, that orders for US customers will not be delayed, and that US manufacturing capacity will not be diverted to China.

Additionally, there is a restriction that total shipments to China and Macau must not exceed 50% of the total volume of the same product shipped to customers in the United States.

All exported products must be verified by an independent third-party testing laboratory based in the US before shipping to ensure the accuracy of technical specifications such as TPP and memory bandwidth. This testing laboratory must have no financial relationship with the exporter or importer and must not be under the control of any power outside the US.

Additionally, as a security measure, the ultimate consignee is required to implement strict 'Know Your Customer' (KYC) procedures and physical security measures, including preventing remote access by restricted parties such as the Chinese military or secret intelligence agencies, and not allowing the unauthorized transfer of trained model weights or algorithms.

Under the Trump administration, it has been reported that an additional 25% commission will be levied on exports of the NVIDIA H200 . Hardware news site Tom's Hardware points out that 'this policy has a strong tendency to treat the Chinese market as a market that accepts the 'leftovers' of the American market.'