The United States considers “globalizing” the AI ​​chip export approval system

# Long Yue

Source: WallStreetCN

The United States is drafting new global approval rules for AI chip exports, planning to require companies including NVIDIA to obtain government approval before shipping chips to any destination worldwide. Meanwhile, the new rules will deeply tie computing power purchases to investment in the U.S.

The new regulations establish a three‑tier approval system based on computing demand: streamlined review for small orders; pre‑approval plus disclosure or inspection requirements for large clusters; and ultra‑large orders exceeding 200,000 chips may oblige the buyer’s country to make official commitments and bind them to U.S. investment.

Following the news, NVIDIA and AMD shares fell during intraday trading.

The U.S. is considering upgrading its AI chip export controls from “restrictions on selected countries” to a **global licensing system**.

According to recent reports by Bloomberg and other media outlets, U.S. government officials are drafting an export control proposal that would require firms such as NVIDIA and AMD to secure U.S. approval before exporting AI chips to **“nearly all destinations globally.”**

People familiar with the matter stated that the new rules are not intended to impose a de facto ban on NVIDIA exports, but to position the U.S. government as the **gatekeeper** of the global AI industrial chain — who can obtain sufficient computing power and on what terms will depend more directly on licensing decisions by the U.S. Department of Commerce.

The U.S. Department of Commerce also proposes that companies from relevant countries must pledge to invest in the U.S. if they wish to purchase large quantities of NVIDIA and AMD chips for AI data centers.

The new rules set up a three‑tier approval process based on computing demand: streamlined for small orders; pre‑approval plus disclosure or inspection conditions for large clusters; and ultra‑large orders over 200,000 chips may require national‑level commitments from the buyer’s country and binding investment in the U.S.

The draft is still under interagency review.

Sources told the media that the text could be substantially revised or temporarily shelved.

After the news emerged, shares of NVIDIA and AMD retreated during Thursday’s session.

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## From “controls over 40 countries” to “global licensing”

The draft would require companies to apply for licenses for exports of **“nearly all”** NVIDIA and AMD AI accelerators, effectively expanding the current framework covering roughly 40 countries to a global scope.

The U.S. Department of Commerce emphasized that this is not a return to the previous administration’s “AI Proliferation Rules.”

The department stated:

“Reports today suggest we are returning to the AI Proliferation Rules. We are not. They were burdensome, overly intrusive, and had catastrophic consequences.”

## “Investment in exchange for licenses”: Middle East model to be institutionalized

The Financial Times reported that the highest tier of the draft will require the buyer’s country to commit to investing in U.S. domestic AI infrastructure in exchange for access to large volumes of advanced chips.

Tying export approvals to investment pledges already has precedent.

Last year, the U.S. reached similar arrangements when approving chip exports to the UAE and Saudi Arabia: the UAE pledged to invest US$1 in the U.S. for every US$1 invested domestically.

The U.S. Department of Commerce noted in a response:

“We have successfully advanced exports through historic agreements in the Middle East, and the administration is currently discussing how to formalize this approach.”

One U.S. official also stated clearly that any regulation introduced by the administration would aim to promote the U.S. technology stack.

Bloomberg also pointed out that approval speed and the stringency of attached conditions will determine whether the impact is “increased paperwork” or “effective technological containment.”

If licenses are issued quickly with few conditions, global AI data center construction may continue, albeit with higher administrative costs.

If approvals are delayed or negotiations prolonged, project planning and delivery schedules could be disrupted.

After the U.S. announced its chip export arrangement with the UAE last year, licensing only began months later and included “reciprocal U.S. investment” conditions.

## Tiered approval: stricter conditions for larger scale

Under the new rules, a phased review process will apply based on the scale of computing power required:

1. **Tier 1: Small purchases (up to 1,000 NVIDIA GB300 GPUs)**

  Relatively simplified review with specific exemption opportunities.

2. **Tier 2: Medium‑to‑large cluster deployments**

  Buyers undergo pre‑review before applying for an export license.

  Conditional requirements may apply, such as full disclosure of business models or permission for U.S. government on-site inspections of data centers.

3. **Tier 3: Ultra‑large deployments (over 200,000 GB300 chips per company in a single country)**

  Requires government involvement from the buyer’s nation.

  The U.S. will demand strict security commitments and “matching” investment in U.S. AI infrastructure.

  For reference, 200,000 GB300 chips matches the total size of the AI infrastructure contract that British firm NScale plans to provide to Microsoft.

Under the new export control framework, chipmakers must meet direct financial allocation requirements to obtain specific licenses.

According to people familiar with the matter, during negotiations over export licenses for high‑end H200 chips in certain markets, NVIDIA CEO Jensen Huang has already agreed to a term:

NVIDIA will hand over **25% of revenue** from those H200 sales to the U.S. government in exchange for export clearance.

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