How did U.S. controls move from A100 and H100 restrictions to H20 and H200 licenses?
U.S. policy began with an immediate A100 and H100 license requirement, became a broader advanced-computing rule, and then tightened to close the test Nvidia had used for China-specific A800 and H800 products. Nvidia developed H20 as another compliant product, but the United States required a license for H20 in April 2025. Although Nvidia later said it had been assured H20 licenses would be granted, it recorded no H20 sales to China-based customers in the quarter it later reported and assumed none in its outlook. Later policy did not create a general reopening: it allowed H200 sales only to approved customers under a case-by-case review with security conditions, and Nvidia received only a small H200 shipment license. Treat a China-specific design or a U.S. license as conditional access, not a durable exemption or broad sales authorization.
Trace the chain
- 1A100 and H100 licensedRegulatory
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 company-specific A100 and H100 license requirement established the initial restriction that BIS soon turned into a general China advanced-computing rule.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 2October 2022 rulesRegulatory
BIS publishes the October 2022 rules on advanced computing chips and chipmaking tools for China
The Bureau of Industry and Security issued a package of export controls restricting advanced computing chips, supercomputer and semiconductor end uses, and chipmaking equipment for China. The advanced computing and supercomputer controls took effect on October 21, 2022, turning the company-specific August letter into a general rule.
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 October 2022 rules created the broader framework that BIS later revised to close a route used by China-specific Nvidia parts.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 3A800 and H800 closed offRegulatory
BIS tightens the chip rules, dropping the interconnect-bandwidth test that A800 and H800 were built around
BIS released updated rules on advanced computing chips and chipmaking equipment. Among the changes it removed interconnect bandwidth as a parameter for identifying restricted chips, which brought Nvidia's China-specific A800 and H800 within the controls, and extended license requirements to more countries. Nvidia's same-day filing listed A100, A800, H100, H800, L40, L40S and RTX 4090 as covered.
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. By dropping the interconnect-bandwidth test, BIS closed the criterion around which A800 and H800 had been designed, prompting another China-specific product response.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 5H20 needs a licenseRegulatory
US requires a license for H20 exports to China; Nvidia flags up to US$5.5 billion in charges
Nvidia disclosed that on April 9 the government required a license for exports of H20 and any chip with its memory or interconnect bandwidth to China, Hong Kong, Macau and D:5 countries, and on April 14 said the requirement would apply indefinitely. Nvidia expected up to about US$5.5 billion of first-quarter charges for H20 inventory, purchase commitments and reserves.
Nvidia Form 8-K ·
On April 9, 2025, the U.S. government, or USG, informed NVIDIA Corporation, or the Company, that the USG requires a license for export to China (including Hong Kong and Macau) and D:5 countries, or to companies…
Why it matters here. The April 2025 requirement made H20 exports contingent on licenses, the mechanism Nvidia later said the U.S. government had assured it would grant.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 6H20 licenses promisedAnnouncement
Nvidia says the US has assured it H20 licenses will be granted and sales to China will resume
After Jensen Huang met officials in Washington and travelled to Beijing, Nvidia said the U.S. government had assured it that H20 export licenses would be granted and that it hoped to start deliveries soon. It also announced an RTX Pro GPU aimed at the China market.
Nvidia Blog ·
The U.S. government has assured NVIDIA that licenses will be granted, and NVIDIA hopes to start deliveries soon.
Why it matters here. Although Nvidia said the U.S. government had assured it that H20 licenses would be granted, Nvidia later recorded no H20 sales to China-based customers and assumed none in its outlook.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 8H200 allowed, 25% cutRegulatory
Trump allows H200 sales to approved Chinese customers with a 25 percent cut for the US
The Trump administration reversed course and said Nvidia could sell its H200 to approved commercial customers in China vetted by the Commerce Department, with 25 percent of the revenue going to the U.S. government. Nvidia welcomed the decision.
The Register ·
Offering H200 to approved commercial customers, vetted by the Department of Commerce, strikes a thoughtful balance that is great for America.
Why it matters here. The approval limited H200 sales to Commerce-vetted Chinese commercial customers, an arrangement BIS then formalized through case-by-case license review subject to security conditions.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 9Case-by-case reviewRegulatory
BIS moves H200 and MI325X exports to China to case-by-case review with security conditions
BIS revised its license review policy so that applications to export Nvidia H200, AMD MI325X and similar chips to China are reviewed case by case if the exporter shows no reduction in capacity for U.S. customers, the Chinese buyer has export-compliance screening, and the product passed independent third-party testing in the United States. The rule took effect on publication.
Bureau of Industry and Security ·
BIS will now review export license applications for the Nvidia H200, AMD MI325X, and similar chips on a case-by-case basis provided certain security requirements are met.
Why it matters here. BIS's case-by-case H200 review policy, conditioned on specified security requirements, was then reflected in a license permitting Nvidia to ship small amounts to specified China-based customers.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 10First H200 licenseRegulatory
US grants Nvidia a license for small H200 shipments to China
The U.S. government granted Nvidia a license to ship small amounts of H200 products to specified China-based customers. Nvidia said the license required U.S. inspection before shipment.
U.S. Securities and Exchange Commission, Nvidia Form 10-K ·
In February 2026, the USG granted a license that would allow us to ship small amounts of H200 products to specific China-based customers.
Why it matters here. The small H200 license issued in February illustrated that the case-by-case policy could permit selected shipments, not unrestricted exports.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
What pushes back
- 4H20 sells compliant
H20 sells below Huawei's chip as supply outruns Chinese demand
Reuters reported that Nvidia had cut H20 prices in China, where oversupply left the chip selling at more than a 10 percent discount to Huawei's competing part. The first export-compliant chip Nvidia built for China after the October 2023 rules was therefore competing on price against the domestic alternative it was meant to hold off.
TrendForce, citing Reuters ·
an oversupply caused the chip to be priced lower than its rival, Huawei, in some cases even at an over 10% discount
What it pushes against. H20's sale as an export-compliant China chip kept a China-specific route open, setting up the later step in which the United States imposed a license requirement.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
- 7No H20 sales
No H20 sales to China in the quarter; Nvidia assumes none in its outlook
Second-quarter fiscal 2026 results showed no H20 sales to China-based customers, a US$180 million release of previously reserved H20 inventory tied to about US$650 million of sales to a customer outside China, and a third-quarter outlook that assumed no H20 shipments to China.
Nvidia Newsroom ·
There were no H20 sales to China-based customers in the second quarter.
What it pushes against. No H20 sales to China that quarter, and an outlook assuming none, showed that the licensing assurances had not restored shipments before policy shifted to allowing H200 sales to approved Chinese customers.
US Export Controls on Nvidia AI Chips to China: A100 to H20 to H200
Changes to this chain
- Proposal #149 rejected (verify:v5): No step operations; the answer's 'following quarter' wording was corrected by hand instead.
- Editor: answer said Nvidia recorded no H20 sales 'in the following quarter'. The entries date the assurance to July 14 and the no-sales result to the second quarter reported on August 27; reworded to 'in the quarter it later reported' (verify:#149).
- Proposal #112 accepted (verify:v4): why of step 5 -> The April 2025 requirement made H20 exports contingent on licenses, the mechanism Nvidia later said the U.S. government had assured it would grant.; why of step 6 -> Although Nvidia said the U.S. government had assured it that H20 licenses would be granted, Nvidia later recorded no H20 sales to China-based customers and assumed none in its outlook.; why of step 7 -> No H20 sales to China that quarter, and an outlook assuming none, showed that the licensing assurances had not restored shipments before policy shifted to allowing H200 sales to approved Chinese customers.
- Proposal #100 accepted (publish:nvidia-datacenter-gpu-roadmap): replace step 4: [counter] H20 sells compliant -> nvidia-china-export-controls#1339: H20's sale as an export-compliant China chip kept a China-specific route open, setting up the later step in which the United States imposed a license requirement.
- Proposal #83 accepted (publish:nvidia-china-export-controls): insert after 6: [counter] No H20 sales -> nvidia-china-export-controls#55: No China H20 sales that quarter, and an outlook assuming none, showed that the assurances had not restored shipments before the next policy action.; answer: U.S. policy began with an immediate A100 and H100 license requirement, became a broader advanced-computing rule, and then tightened to close the test Nvidia had used for China-specific A800 and H800 products. Nvidia developed H20 as another compliant product, but the United States required a license for H20 in April 2025. Although Nvidia later said it had been assured H20 licenses would be granted, it recorded no H20 sales to China-based customers in the following quarter and assumed none in its outlook. Later policy did not create a general reopening: it allowed H200 sales only to approved customers under a case-by-case review with security conditions, and Nvidia received only a small H200 shipment license. Treat a China-specific design or a U.S. license as conditional access, not a durable exemption or broad sales authorization.
- Proposal #13 accepted (verify:v1): why of step 7 -> The approval limited H200 sales to Commerce-vetted Chinese commercial customers, an arrangement BIS then formalized through case-by-case license review subject to security conditions.; why of step 8 -> BIS's case-by-case H200 review policy, conditioned on specified security requirements, was then reflected in a license permitting Nvidia to ship small amounts to specified China-based customers.
- 9 step labels shortened by the editor
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
- Nvidia Data Center GPUs: Hopper, Blackwell and Vera Rubin
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.