In practical terms, the global diffusion of the semiconductor supply chain means that the US cannot impose effective export controls on its own in order to halt China’s technological advancement. With dozens of countries involved in chip design, manufacturing and delivery, Washington must rely on key allies and partners to enforce restrictions at strategic chokepoints. During the Biden administration, this understanding guided export control policy, where multilateral alignment became a central tenet. It was widely acknowledged that without international coordination unilateral controls would risk circumvention, invite backfilling and undermine strategic goals. The second Trump administration has taken a very different approach to export controls. While technology restrictions remain at the heart of the US's strategy towards China, there have been notable changes. Firstly, the administration is much more willing to use export controls unilaterally and extraterritorially. The Bureau of Industry and Security (BIS) plans to put pressure on allies such as Japan and the Netherlands to bring them into closer alignment with US export controls. Malaysia, Singapore and Taiwan have already tightened their national export controls under pressure from Washington in order to prevent the re-routing of US chips to China. The agency has also informed South Korean and Taiwanese chip manufacturers that it may revoke the current waivers allowing them to import certain US technologies into their China-based facilities. Secondly, the Trump administration has started using export controls as explicit bargaining chips. This was exemplified by major AI deals with the Gulf states and the lifting of restrictions on chip design software as well as resuming the sale of Nvidia’s H20 AI chips to China. Under pressure from Beijing's rare earth controls, this marked a dramatic reversal of the Trump administration's previous hawkish stance on China. This policy shift marks a departure from previous administrations, which viewed export controls as non-negotiable instruments of national security. Under Trump, the distinction between strategic and transactional export controls is becoming increasingly blurred. This may embolden Beijing to demand further concessions from Washington and European countries who hold chokepoints in the semiconductor supply chain. Finally, the return of Nvidia’s chips to the Chinese market indicates a broader paradigm change. As set out in the White House’s AI Action Plan, the administration is set to prioritise the diffusion and commercial scale of technology over long-term strategic denial. In this new context, export controls are no longer considered the default method of constraining Chinese technological advancement. Instead, the administration has echoed industry arguments that maintaining global market access for US firms such as Nvidia is crucial for preserving American leadership and AI standards. While the administration seeks to ensure that its allies are building AI on American technology, its transactional approach to export controls, a penchant for extraterritoriality and an inconsistent trade policy could complicate coalition-building.
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