BIS moves H200-class AI chip exports to China to case-by-case review

The Commerce Department's Bureau of Industry and Security published a rule on January 15, 2026 that replaces the presumption of denial for certain advanced computing chips going to China and Macau with case-by-case licensing. The thresholds cover NVIDIA's H200 and AMD's MI325X. For traders this is the legal basis for H200 sales into China, and it came with conditions on supply, buyer compliance and third-party testing.

• Covers chips under TPP 21,000 and DRAM bandwidth under 6,500 GB/s, including the H200
• Applicants must show no reduction in US supply and that the Chinese buyer has compliance procedures
• Products must pass independent third-party testing in the US
• Presumption of denial still applies to Country Group D:5 destinations