Workshop A — An Updated Roadmap to Complying with the China Advanced Computing and Semiconductor Rule: A Deep Dive into TGLs, Impacted ICs, Gap Analysis and More Requirements
DLA Piper LLP
Senior Counsel, Trade Compliance
Workshops are offered In-Person only
According to reports, the Biden Administration is set to further tighten restrictions on the export of semiconductor manufacturing gear to China, with new restrictions expected to be announced as early as later this year. The rules may double the number of machines that require special licenses for export. This workshop will dig deeply into the details behind creation of renovated semiconductor rule compliance programs and corporate due diligence efforts.
- Updating licensing requirements for items controlled under ECCNs 5A002 or 5D002 that meet or exceed the performance parameters of the new ECCNs 3A090 or 4A090
- Updating licensing requirements for mass market encryption hardware and software items controlled under ECCNs 5A992 or 5D992
- Restrictions on U.S. persons activities: U.S. persons (citizens, permanent residents, asylees, and refugees) that support the development or production of integrated circuits (IC’s) in China now requires a license
- What kind of ICs are involved?
- What ECCNs are relevant?
- Are any license exceptions available?
- New foreign direct product rules focused on otherwise uncontrolled foreign-origin content for advanced computing and supercomputer-related applications in China
- Expanded “Entity List FDP Rule” (§ 734.9(e)(2)
- New “Supercomputer FDP Rule” (§ 734.9(i)
- New “Advanced Computing FDP Rule” (§ 734.9(h)
- Whether a product is truly a direct product of US-origin “technology” and “software” per the EAR
- Licensing policies and Temporary General Licenses
- Gap analysis: Updating compliance programs to make sure