Policy Review of Semiconductor Manufacturing Equipment:
The Art of Balancing Economic and National Security

Key Semiconductor Policy Strategies

3 Dangerous PRC Semiconductor Manufacturers

Executive Summary

The key policy perspectives and stakeholders on the US-China semiconductor export control debate can be organized into three categories: No Restrictions, Balanced Approach, and Partial Decoupling.

Restriction on the export of semiconductor manufacturing equipment (SME) to the People’s Liberation Army of China and its affiliates is already required by US and international law, but some US policy actors seek to undermine, weaken, and delay the application of these rules.

The US Department of Commerce Bureau of Industry and Security must make Entity List designations for three firms affiliated with the People’s Liberation Army (PLA) of China: Semiconductor Manufacturing International Corporation (SMIC), Yangtze Memory Technologies (YMTC), and ChangXin Memory Technologies (CXMT).



“If sanctions against SMIC are put into place, the export of equipment from US semicon equipment companies such as Lam Research and Applied Materials will become all but impossible. As well as being a negative for the semicon equipment industry, such developments would be unfavorable for fabless players and chipmakers in China such as YMTC and CXMT.” Read more.


“One of the most powerful ways to deter the advance of the PRC military is to deny it the means of production. If the PRC is denied SME, it can’t produce its own chips. While that doesn’t stop the PRC’s long march to become self-sufficient in semiconductors, it certainly slows it down.” Read more.

Pradeep’s Techpoints

“According to Dr. Layton, 3D NAND and DRAM are the essential elements for PCs, data centers, missiles, drones, satellites, smartphones, communications networks, cloud, AI, etc… Understandably, these technologies have emerged as policy flashpoints because these are areas where the USA still has some technological advantage. Policy makers can slow their integration into the PRC’s weapon systems. While some high-end manufacturing capability remains in the USA, the global market share for US manufacturing has been halved in the last decade, mostly due to the outsourcing of foundries to other countries for the sake of cost savings and economic conditions.”