Why did AMD pursue China-specific AI chips instead of simply shipping its standard Instinct GPUs?
AMD pursued China-specific products because its regular high-end Instinct exports had become license-controlled and the performance rules kept changing. The U.S. first required licenses for Nvidia's A100 and H100 and then gave AMD a similar notice for MI250 and MI250X. BIS turned those restrictions into threshold-based rules, while AMD said it saw an opportunity for a compliant AI chip. But the October 2023 update removed the interconnect test that China-specific parts relied on, and Commerce later declined to clear AMD's cut-down accelerator because it remained too capable. Even the MI308 was subsequently made subject to a new license requirement, showing that a China-specific design did not by itself secure permission to ship.
Trace the chain
Initial restrictions
- 1Nvidia license noticeRegulatory
US imposes a license requirement on Nvidia A100 and H100 exports to China
Nvidia disclosed that the U.S. government had imposed, effective immediately, a license requirement for exports of its A100 and forthcoming H100 chips to China, including Hong Kong, and Russia, along with systems containing them and any future chip at A100-level performance. Nvidia said it did not sell to Russia and that the rule could affect H100 development and A100 support.
Nvidia Form 8-K ·
On August 26, 2022, the U.S. government, or USG, informed NVIDIA Corporation, or the Company, that the USG has imposed a new license requirement, effective immediately, for any future export to China (including Hong…
Why it matters here. The U.S. requirement for Nvidia's A100 and H100 exports set the immediate context for AMD to confirm that MI250 and MI250X shipments faced a similar notice.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 2MI250 needs licenseRegulatory
AMD told it needs a license to ship Instinct MI250 GPUs to China
Days after Nvidia disclosed a license requirement for the A100 and H100, AMD confirmed it had received a similar notice covering the Instinct MI250 and MI250X, while the older MI100 was unaffected. AMD said the impact on its data center business would be marginal, since most of its compute GPUs went into US and European supercomputers, and disclosed the requirement in its third-quarter 10-Q.
Tom's Hardware ·
AMD has notified its Chinese operations that from now on, it will have to obtain an export license from the U.S. Department of Commerce to sell its Instinct MI250 and MI250X compute GPUs to Chinese clients, reports…
Why it matters here. The notice made AMD's MI250-class China exports license-dependent, so BIS's published rules defined advanced-computing restrictions through performance and interconnect thresholds.
US Export Controls on AMD's AI Chips in China: From the MI250 License to MI308 and MI325X
Finding a compliant part
- 3Threshold rules publishedRegulatory
BIS publishes the October 2022 rules on advanced computing chips and chipmaking tools
The Commerce Department turned the August letters into a published rule: advanced computing chips above a performance and interconnect threshold, the supercomputers they feed and the equipment to make them all needed licenses for China. The thresholds caught the MI250 class and set the ceiling under which AMD, Nvidia and Intel would design China-specific parts.
Bureau of Industry and Security ·
The Department of Commerce's Bureau of Industry and Security (BIS) is implementing a series of targeted updates to its export controls as part of BIS's ongoing efforts to protect U.S. national security and foreign…
Why it matters here. The threshold-based restrictions made compliance product-specific, so AMD said it would follow the controls while pursuing an opportunity for a compliant AI chip.
US Export Controls on AMD's AI Chips in China: From the MI250 License to MI308 and MI325X
- 4Compliant-chip opportunityAnnouncement
Lisa Su: China is an 'important' market and AMD sees room for a compliant AI chip
On the second-quarter 2023 call, as AMD prepared to ramp the MI300, Su said the company would be fully compliant with US export controls but saw an opportunity to develop an accelerator specifically for Chinese customers, following Nvidia's A800 and H800 and Intel's Gaudi variant. That product became the MI308.
CNBC ·
Lisa Su, CEO of AMD, said on an earnings call late Tuesday that China is an "important" market and that the semiconductor giant wants to be fully compliant with U.S. export controls.
Why it matters here. AMD's plan to serve China with a compliant product depended on the applicable limits, so BIS's next update could undermine the design approach China-specific parts used.
US Export Controls on AMD's AI Chips in China: From the MI250 License to MI308 and MI325X
Rules tighten again
- 5Interconnect loophole closedRegulatory
BIS tightens the chip rules, dropping the interconnect test that the China-specific parts relied on
The October 2023 update replaced the interconnect-bandwidth parameter with a total processing performance and performance density test, closing the loophole that Nvidia's A800 and H800 had used, and added a notification requirement for chips just under the line. AMD's MI300 family fell above the new threshold, so any China part would have to be cut down much further.
Bureau of Industry and Security ·
Based on public comments, recent technological developments, and analysis of the prior rule's national security impact, the AC/S IFR removes 'interconnect bandwidth' as a parameter for identifying restricted chips.
Why it matters here. Dropping the interconnect parameter closed the loophole those parts relied on, so Commerce declined to clear AMD's cut-down accelerator because it was still too capable.
US Export Controls on AMD's AI Chips in China: From the MI250 License to MI308 and MI325X
- 6Cut-down chip rejectedReport
Bloomberg: AMD's made-for-China accelerator is still too fast and will need a license
Bloomberg reported that the Commerce Department had declined to clear AMD's cut-down AI chip for sale in China because it remained too capable, meaning AMD would have to apply for a BIS license rather than ship under the notification route. The report was the first public sign that the MI308 would live or die by license decisions.
CNBC ·
American semiconductor company Advanced Micro Devices has failed in getting a made-for-China AI chip past U.S. regulators and will need to apply for an export license, Bloomberg reported Tuesday.
Why it matters here. The refusal to clear the cut-down chip left China sales dependent on licensing, so the April 2025 requirement could halt MI308 exports and trigger a charge warning.
US Export Controls on AMD's AI Chips in China: From the MI250 License to MI308 and MI325X
- 7MI308 needs licenseRegulatory
New license requirement hits the MI308; AMD warns of up to $800 million in charges
A day after Nvidia disclosed the H20 license requirement and a $5.5 billion charge, AMD filed an 8-K saying the same new rule covered exports of its MI308 to China, Hong Kong, Macau and other D:5 countries. It expected up to $800 million of inventory, purchase-commitment and reserve charges, said it would apply for licenses with no assurance of approval, and its shares fell more than 7 percent.
AMD Form 8-K (SEC) ·
The Export Control applies to the Company’s MI308 products. The Company expects to apply for licenses but there is no assurance that licenses will be granted. The Company expects that the Export Control may result in…
Why it matters here. The MI308 halt showed that tailoring a chip for China did not itself exempt AMD from subsequent U.S. licensing decisions.
US Export Controls on AMD's AI Chips in China: From the MI250 License to MI308 and MI325X
Timelines in this chain
- US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- US Export Controls on AMD's AI Chips in China: From the MI250 License to MI308 and MI325X
- AMD Instinct: From MI300X to Helios and the Gigawatt Deals
A chain is written by the editor from entries already published on the timelines above, each of which was read against its source before publication. The chain changes when those entries do. Data and terms.