US–China Chip War Tracker: Export Bans, Rare-Earth Retaliation, and Where Things Stand

The US and China are fighting a trade war inside a single industry — the chips that run artificial intelligence — and this page keeps the running score. Who can sell what to whom, what each side just restricted, and where the leverage sits. We update it as the rules change; the "Updated" date at the top tells you how fresh it is.

The shape of the fight: Washington controls the world's most advanced AI chips (Nvidia's, mostly) and wants to keep them out of Chinese hands. Beijing controls the processing of rare-earth elements the chip industry depends on and has learned to license them the way the US licenses chips. Each new restriction on one side gets answered by the other — usually within days. The twist as of July 2026: Beijing has also been restricting its OWN companies from buying US chips, as part of a tech self-sufficiency push — and that's now starting to crack too.

Recent timeline: - May 2025 — The US Commerce Department's Bureau of Industry and Security assesses that Huawei's Ascend AI chips were developed in violation of US export controls. - December 8, 2025 — Trump decides to permit sales of Nvidia's H200 — the most advanced AI chip legally available to China. - January 15, 2026 — A Federal Register rule codifies the H200 opening with strings attached: case-by-case license review (instead of presumed denial) for chips including the H200 and AMD's MI325X, China-bound H200 volumes capped at 50% of US shipments, a 25% tariff routed via Taiwan, and US-supply certifications. The same rule introduces total-processing-power thresholds that fundamentally tighten what counts as a controlled chip. - Late May 2026 — New US rules target Nvidia's most sophisticated processors, including the Blackwell series: any transfer to an entity headquartered in China or Macau now requires an export license. - June 8, 2026 — The Pentagon publishes an updated Section 1260H list of "Chinese Military Companies" operating in the US, adding 65 entities: 17 new parent companies and 48 subsidiaries. The additions run far deeper into China's civilian economy than earlier rounds — Alibaba, Baidu, BYD, NIO, battery makers CALB and EVE Energy, solar manufacturers JA Solar and Trina Solar. The list now names 188 companies. Listing is not a sanction: it bars the Defense Department from contracting directly with those firms, with the ban on buying their products through third parties following in June 2027. Alibaba said it would "take all available legal action"; Baidu said it would use every option to get removed (CNBC; WilmerHale; Fortune). - June 22, 2026 — Beijing answers, two weeks later, with Announcement No. 23, adding ten American entities to its export-control list — including defense contractors (Ball Aerospace, Oshkosh Defense, L3Harris Maritime Services) and, pointedly, the US rare-earth miners MP Materials and USA Rare Earth. The measure is a full ban on dual-use exports to those firms, not merely a licensing requirement, and it reaches parties anywhere in the world handling Chinese-origin dual-use items. MP Materials runs Mountain Pass in California, the only producing rare-earth mine in the United States, and took a $400 million equity investment from the Department of Defense; USA Rare Earth is building a mine-to-magnet chain in Texas (Al Jazeera; Washington Post; Morgan Lewis). - July 1, 2026 — China's export-control regime adds an enforcement layer: a formal mechanism encouraging organisations and individuals to report suspected violations of dual-use controls on strategic minerals. Less dramatic than a blacklist, more durable — it turns a rule into a surveillance system (Morgan Lewis). - July 8, 2026 — Chinese authorities notify Alibaba, ByteDance, DeepSeek and other major AI firms that they'll be permitted to buy Nvidia H200 chips, with total approved volume expected to stay under 200,000 units, restricted to AI model training, and subject to case-by-case government review of quantities and use cases (Bloomberg, citing The Information, July 8, 2026). Beijing had been quietly blocking its own firms from buying the H200 even after the US cleared it for export, as part of a push for domestic chip self-sufficiency — this is the first sign that stance is loosening, driven by surging Chinese demand for AI compute. - July 24, 2026 — Beijing extends the dual-use export ban to Europe. China's Ministry of Commerce adds 14 EU entities to its export-control list, ordering Chinese exporters to stop supplying them immediately and barring anyone anywhere from transferring Chinese-origin dual-use items to them; exports are possible only by exceptional application to the ministry. The named entities span Germany, the Czech Republic, Italy, France, Lithuania, the Netherlands, Bulgaria and Poland — Rheinmetall AG, Tatra Trucks, Vigo Photonics and Wrocław University of Science and Technology among them — and work in defence, drones, photonics, semiconductors, lasers and maritime technology. Beijing presented it as a direct answer to the EU's decision to sanction 14 Chinese firms over alleged support for Russia's war in Ukraine (CGTN; Caixin Global; MLex; OSW, July 2026). - Ongoing — China's Ministry of Commerce requires licenses for exports of Chinese-origin rare earths, or products made with them, when linked to advanced chip development — defined as logic chips at 14 nanometers or below, or memory with 256 or more layers.

The scoreboard so far: Nvidia commanded over 90% of China's AI-chip market in 2023; by early 2026 its share had roughly halved, and the company has warned investors that export controls could cost it up to several billion dollars in a single quarter. On the other side, SMIC and Huawei are ramping up domestic AI-chip production with heavy state investment, and Beijing has imposed a domestic compute mandate — a growing share of Chinese AI workloads must, by rule, run on Chinese hardware. The July 8 H200 approval doesn't reverse that mandate — it's a narrow, volume-capped exception for firms whose compute needs currently outstrip what Chinese chips can supply.

One pattern worth naming, because it repeats: the loudest US moves are not always tariffs or chip rules. The 1260H list is a procurement blacklist with no sanctions attached, and Beijing still treated it as an act of economic war, answering within a fortnight by cutting off the two American companies trying hardest to break China's rare-earth grip. Each side now reaches past the chip itself — to the minerals under it, the buyers around it, and the contractors who never touch it.

Why this page will keep growing: neither side's strategy works quickly. Export controls take years to bite; building a domestic chip industry takes longer. That means every few weeks brings a new rule, a new blacklist, or a new workaround — and each one lands right here.

July 21, 2026 — The mirror goes up. The Financial Times reports that China's Ministry of Commerce has been consulting Alibaba, ByteDance, Zhipu, Huawei and other domestic AI and chip firms on a Chinese export-control regime, designed to stop the country's leading technology and start-ups being acquired by the West. Under discussion: limits on foreign access to China's advanced AI models and on overseas downloads of model weights, a bar on moving key AI training data out of the country, a block on overseas chipmakers producing advanced semiconductors from Chinese designs, and potential restrictions on foreign acquisition of agentic AI technology. Qualcomm and TSMC came up in the discussions. Nothing is final — regulators are still weighing industry feedback, and the rules would most likely appear in the next revision of China's export control catalogue. But the direction is the story: Beijing spent four years arguing that export controls on technology are protectionism dressed as security, and is now writing its own.

July 24, 2026 — The war gets a third party. Until now this page has had two columns: Washington restricts chips, Beijing restricts minerals. The Ministry of Commerce's decision to ban dual-use exports to 14 EU entities adds a third, and it is worth being precise about what happened, because the chip angle is not the headline anyone led with. The listed companies are mostly defence-adjacent — Rheinmetall AG in Germany, Tatra Trucks in the Czech Republic — but the list also reaches straight into the supply chain this page tracks: photonics, semiconductors and lasers, including Poland's Vigo Photonics and a Polish technical university. The stated trigger was European, not American: the EU had sanctioned 14 Chinese firms over alleged support for Russia's war in Ukraine, and Beijing answered with the same number in the other direction (CGTN; Caixin Global; OSW).

The mechanism is the one Beijing used on MP Materials in June — a full ban rather than a licensing requirement, with extraterritorial reach over anyone handling Chinese-origin dual-use goods. What is new is the target. Europe has spent three years trying to hold a middle position in the chip war: ASML's lithography machines are the single most important choke point in advanced chipmaking, and Brussels has restricted them under American pressure while insisting it was not picking a side. Being placed on a Chinese export-control list is Beijing's way of saying the middle position has closed. The gap between a licence and a chip

Both governments spent the first half of 2026 adjusting who is *allowed* to trade H200s. It is worth checking, separately, whether any actually changed hands - because the answer is mostly no.

On July 14, 2026, Under Secretary of Commerce for Industry and Security Jeffrey Kessler told a congressional committee that H200 shipments to China had started, and then immediately deflated the point: "There have been minimal exports of any H200s to China so far." Asked for a number, he described it as very few (Reuters, July 14, 2026).

Hold that against the timeline above. Washington cleared H200 sales case-by-case from January 15, 2026. Beijing lifted its own block on July 8, 2026, telling Alibaba, ByteDance and DeepSeek they could buy. Both permission slips exist. The chips still are not arriving in quantity.

That matters for how you read any headline in this story. "US approves chip sales to China" and "China allows firms to buy Nvidia" are both accurate and both describe paperwork. The physical trade is a separate variable, it is measured in units rather than announcements, and by the US government's own testimony it is currently close to nothing.

The same hearing exposed the enforcement side, which is where the real argument now sits. Representative Bill Huizenga went after Commerce guidance issued on May 31, 2026 concerning Blackwell chips - a generation above the H200 - which he read as telling Chinese companies they could keep Blackwells acquired "through either smuggling or other loopholes." He wanted to know why Commerce had not told Beijing plainly that they "cannot keep the Blackwells," and did not accept the answers he got: "That is just a frickin' circle that you talk in, and I'm sorry but this is unacceptable" (Reuters, July 14, 2026).

Strip the theatre and there is a substantive question underneath. An export-control regime is only as strong as the recovery mechanism behind it. If restricted chips that reached China by smuggling or through a subsidiary loophole simply stay there, then the control is a tax on the honest route rather than a barrier - which is roughly what the licensing-versus-shipments gap looks like from the other direction too.

* The November 10 clock (updated August 23, 2026)

Most of the entries on this tracker are things a government did. This one is a thing a government stopped doing, on a timer. On October 9, 2025, China's Ministry of Commerce published Notice 61, which extended Chinese export-licence requirements to rare earths and to products made with them — including a 0.1% de minimis threshold. Read plainly, that means a factory in Germany, Taiwan or Ohio that builds a component with Chinese-origin rare earth content worth at least 0.1% of the finished product's value needs Beijing's permission to export it to a third country. It is one of the most far-reaching extraterritorial claims ever attached to a raw material, and it borrows the logic of US export controls almost exactly.

Beijing then suspended the October 9 measures on November 7, 2025 for one year, until November 10, 2026, while the two sides negotiated and while MOFCOM built out the licensing machinery. The suspension is the reason most supply chains have spent 2026 treating the rule as theoretical.

As of August 23, 2026, that suspension has 79 days left. Nothing needs to be announced for the rule to return — the default is that it does. Which makes this the rare item on a chip-war tracker where the news event is scheduled in advance and the uncertainty is entirely about whether someone intervenes. Watch for a MOFCOM extension notice, a replacement framework, or a negotiated carve-out. Absence of all three is the story.

Washington stops writing rules and starts buying plants (updated September 4, 2026)

Almost everything else on this tracker is a restriction — one government telling companies what they may not ship. The last two weeks of August 2026 produced the other kind of move: money, and specifically equity.

Start with why gallium. On December 3, 2024, China's Ministry of Commerce banned exports of gallium, germanium, antimony and superhard materials to the United States — one day after Washington announced a fresh round of controls on advanced chips and chipmaking equipment. It was retaliation aimed at a genuine chokepoint: China holds roughly 94% of global gallium supply, 83% of germanium and 56% of antimony. Gallium is not exotic in defence terms; it goes into the semiconductors behind air and maritime radars, ground-based missile defence, secure satellite and tactical communications, and the infrared sensors used for missile guidance and thermal imaging.

That ban was then suspended — Beijing paused it in November 2025, with the suspension running to late November 2026, as part of the same truce that paused Notice 61. Which is the structural point this tracker keeps returning to: the leverage was never removed, only switched off on a timer.

So on August 31, 2026, the US Department of War announced an estimated $174 million equity investment in a gallium production facility at Alcoa Corporation's Wagerup alumina refinery in Western Australia, partnered with Japan's Sojitz Corporation, the Japanese government and Export Finance Australia, and targeting 100 metric tons of gallium a year. Construction began in late August after a groundbreaking attended by Australian, Japanese and American officials. Note the word equity: this is not a grant or an offtake contract but a government taking an ownership position in a private refinery on a third country's soil — the same instinct that produced the Pentagon's stake-taking in domestic rare-earth processing, exported.

It arrived inside a broader fortnight. On August 20, 2026, the US Energy Department's Office of Critical Minerals and Energy Innovation announced $500 million across seven projects to expand critical-mineral processing, battery manufacturing and recycling — the third round under its battery materials programmes — with Lilac Solutions taking $100 million for a direct-lithium-extraction plant on Utah's Great Salt Lake, sized at 5,000 tons a year in phase one and aiming at first production in 2028. The same day, Tokyo proposed expanding JOGMEC's mandate so the state minerals body can invest in overseas projects on its own account rather than only in partnership with Japanese companies.

What ties it together is a change of theory. For three years the Western answer to Chinese mineral leverage was diplomatic: stockpiles, friend-shoring language, and hope. The August moves treat the supply chain as something states have to own outright, because the market signal is brutal — indium went from around $250 a kilogram to about $805 after Beijing's February 2025 restrictions (Asia Times, September 4, 2026).

Two cautions before anyone calls this independence. First, scale: 100 tons of gallium a year is a defence-supply hedge, not a replacement for Chinese output, and the Utah lithium plant does not produce anything until 2028 — mineral processing runs on construction timelines, while export controls run on press-release timelines. Second, timing: the one-year US-China trade truce lapses in November 2026, the same month both Chinese suspensions expire. If those talks break down, the restrictions come back on plants that are still holes in the ground.

The thing worth watching is therefore not the dollar figures but the calendar. November 2026 is where the truce, Notice 61's suspension and the gallium ban suspension all land within a few weeks of each other, and none of them requires anybody to do anything for the restrictions to return.