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.
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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.
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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.
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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.
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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.
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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.
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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.
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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).
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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**
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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.
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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).
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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.
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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.
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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).
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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.
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The November 10 clock (updated August 23, 2026)
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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.
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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.
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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.
Is the Foundry Due Diligence Rule still in force in August 2026?
On paper, yes — it was issued in January 2025 and has not been repealed. The problem is that it first appeared inside the AI Diffusion Rule, which Washington said in May 2025 it would not enforce, leaving foundries unsure whether the due-diligence obligation went with it. That ambiguity is exactly what House Select Committee on the CCP chairman John Moolenaar asked the Bureau of Industry and Security to end in his August 6, 2026 letter to Under Secretary Jeffrey Kessler, reported by Reuters on August 10, 2026. As of this update, BIS has not published the clarifying guidance he requested.
Did China restrict exports to European companies too?
Yes. On July 24, 2026, China's Ministry of Commerce added 14 EU entities to its export-control list, banning dual-use exports to them outright rather than merely requiring licenses. The list covers firms in Germany, the Czech Republic, Italy, France, Lithuania, the Netherlands, Bulgaria and Poland — including Rheinmetall AG, Tatra Trucks, Vigo Photonics and Wrocław University of Science and Technology — working in defence, drones, photonics, semiconductors, lasers and maritime technology. Chinese exporters had to stop supplying them immediately, and the ban reaches any party anywhere handling Chinese-origin dual-use items, with exceptions only by application. Beijing described it as retaliation for the EU sanctioning 14 Chinese companies over alleged support for Russia's war in Ukraine (CGTN; Caixin Global; MLex).
Is China introducing its own chip and AI export controls?
It is preparing to. On July 21, 2026 the Financial Times reported that regulators led by China's Ministry of Commerce have been consulting major domestic AI and chipmaking companies — including Alibaba, ByteDance, Zhipu and Huawei — on measures to stop China's advanced technologies and leading start-ups being acquired by the West. The proposals under discussion include restricting foreign access to China's advanced AI models and overseas downloads of model weights, preventing key AI training data from leaving the country, blocking overseas chipmakers from producing advanced chips based on Chinese designs, and possible curbs on foreign acquisition of agentic AI technology. They are not yet in force; they could be folded into the next revision of China's export control catalogue.
What is the Pentagon's 1260H list, and why does it matter for chips?
It is the Defense Department's public list of "Chinese Military Companies" operating in the US, required by Section 1260H of the FY2021 NDAA. On June 8, 2026 the Pentagon added 65 entities — 17 parents and 48 subsidiaries, among them Alibaba, Baidu, BYD, NIO, CALB, EVE Energy, JA Solar and Trina Solar — bringing the list to 188 companies. It imposes no sanctions; it bars direct Defense Department contracting, with third-party procurement barred from June 2027. Its chip-war significance is what it triggered: two weeks later Beijing put ten US firms, including rare-earth miners MP Materials and USA Rare Earth, under a full dual-use export ban.
What is the US–China chip war?
A running exchange of export restrictions in which the US limits China's access to advanced AI chips and chipmaking technology, and China retaliates with export controls on the rare-earth elements and critical minerals the chip industry depends on — while also, until recently, restricting its own firms from buying US chips as part of a self-sufficiency drive. It has escalated steadily since 2022 and sharply through 2025–2026.
Can Nvidia sell AI chips to China right now?
Yes, with limits on both sides. Under the January 15, 2026 US rule, H200-class chips are reviewed case-by-case, with China-bound volumes capped at 50% of US shipments. Since late May 2026, Blackwell-class processors require a US export license for any China- or Macau-headquartered buyer. On the Chinese side, Beijing told major firms like Alibaba, ByteDance and DeepSeek on July 8, 2026 that they can now buy H200s (under 200,000 units total, for AI training only) — reversing its own prior block on the chip. Nvidia's share of China's AI-chip market has fallen from over 90% in 2023 to roughly 50% in early 2026. Permission is not delivery, though: on July 14, 2026 Under Secretary of Commerce Jeffrey Kessler told Congress "there have been minimal exports of any H200s to China so far" (Reuters).
Why was China blocking its own companies from buying Nvidia chips?
As part of a domestic compute mandate requiring a growing share of Chinese AI workloads to run on Chinese-made hardware, aimed at building self-sufficiency in chips. Chinese AI firms' demand for compute has outpaced what domestic chipmakers like Huawei and SMIC can supply, which is why Beijing began easing the block on July 8, 2026 — starting with a volume-capped allowance for H200 purchases.
What are China's rare-earth restrictions?
Exports of Chinese-origin rare earths — or products made with them — require a government license when linked to the development or manufacture of advanced chips, defined as logic at 14nm or below or memory with 256+ layers. On June 22, 2026, China also added ten US firms to its export-control list, including rare-earth miners MP Materials and USA Rare Earth.
Is China catching up on chips?
It is trying to substitute rather than catch up outright: SMIC and Huawei are ramping domestic AI-chip production with state backing, and a government mandate requires a growing share of Chinese AI computing to run on domestic hardware. The US assessed in May 2025 that Huawei's Ascend chips were developed in violation of US export controls.
Have Nvidia's H200 chips actually been delivered to China?
Barely. Under Secretary of Commerce for Industry and Security Jeffrey Kessler testified on July 14, 2026 that shipments had begun but that "there have been minimal exports of any H200s to China so far," describing the volume as very few (Reuters, July 14, 2026). This is despite the US clearing H200 sales case-by-case since January 15, 2026 and Beijing lifting its own block on July 8, 2026. Approval on both sides has not yet translated into hardware arriving in quantity.
What is the Blackwell loophole?
A dispute over Commerce Department guidance issued on May 31, 2026 relating to Nvidia's Blackwell processors, a generation more advanced than the H200. At a July 14, 2026 hearing, Republican Representative Bill Huizenga said the guidance indicated Chinese companies could keep Blackwell chips they had obtained "through either smuggling or other loopholes," and criticised Commerce for not telling China plainly that they "cannot keep the Blackwells." Since late May 2026, Blackwell-class chips have required a US export licence for any buyer headquartered in China or Macau; the argument is about enforcement and recovery, not about the rule itself.
What is China's 0.1% rare-earth rule and when does it take effect?
China's Ministry of Commerce Notice 61, published October 9, 2025, requires a Chinese export licence for any product made outside China whose Chinese-origin rare earth content is worth 0.1% or more of the product's value, before it can be shipped to a third country. MOFCOM suspended the October 9 measures on November 7, 2025 for one year, until November 10, 2026. Unless Beijing extends, replaces or modifies that suspension, the rule returns automatically on November 10, 2026.
“Washington licenses the chips, Beijing licenses the dirt they're made with — and the invoice keeps bouncing back and forth.”