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US advanced-computing export controls

Statute United States

US Bureau of Industry and Security controls under the Export Administration Regulations restricting the export, reexport and in-country transfer of advanced computing chips, semiconductor manufacturing equipment and related technology, using performance thresholds, end-use and end-user screening, and the Entity List.

The US advanced-computing export controls are administered by the Bureau of Industry and Security under the Export Administration Regulations, and they are the most operationally intrusive regime in this catalog for the companies they touch. They restrict the movement of advanced computing integrated circuits, semiconductor manufacturing equipment and associated technology, using technical performance thresholds to define what is controlled.

  • Performance thresholds - Whether a chip is controlled depends on measurable characteristics, so specifications are compliance-relevant facts.
  • End-use and end-user screening - Obligations attach to the seller, including the Entity List and know-your-customer red flags.
  • Extraterritorial reach - The Foreign Direct Product Rule extends control to some goods made abroad with US technology.
  • Frequently revised - Thresholds and scope have been updated repeatedly since 2022.

This regime deserves careful handling in any assessment of semiconductor API practice, and The State of Compute & Hardware APIs gives it exactly that. It is the only regulation in this research that gives a company a legitimate reason to publish less. When performance characteristics are licensing triggers and screening duties attach to whoever responds, a public, self-serve, machine-readable surface enumerating capabilities and answering anonymously is a genuine compliance question rather than a hypothetical one.

What it does not explain is the shape of the gap. Nothing in export control prevents a company from publishing part lifecycle status, errata, a documented error envelope or an idempotency key — none of which is controlled technology, and all of which are missing across the silicon layer.

Referenced in API Evangelist papers

This regulation shows up in my published research. These reports read the machine-readable evidence provider by provider — and put this regulation in the context of a real sector.

The State of Compute & Hardware APIs

The one regime in the series that argues AGAINST publishing — performance thresholds are licensing triggers, and end-user screening attaches to the seller.