US-China AI Semiconductor Regulation Calendar 2024-2026: The Symmetry, on One Page

Hello, this is Hamamoto from TIMEWELL. From 2024 through 2026, export controls have moved along three main axes: the United States, China, and the EU. Layered on top of them, quarter by quarter, are the measures of the aligned countries: Japan, the Netherlands, the UK, India, and Taiwan. The three principals draft the rules, and the aligned countries build operations that produce an equivalent effect within their own domestic law. That is the basic structure.

At first glance it can all look like an unrelated stream of headlines. But the moment you place the events on a timeline, a clear pattern surfaces: one country moves, and another moves symmetrically right after. The day after the US updated its Entity List in December 2024, China banned the export of certain minerals to the US. That was not a coincidence. In this article I lay out the major regulations on a single calendar and explain how they interlock, in terms a newcomer can follow. Rather than framing this as a "US-China conflict," I treat it neutrally, as symmetric institutional responses between sovereign states.

What you will learn here

• A single calendar of the major export controls from 2024 through June 2026
• The structure by which US measures and Chinese responses fire symmetrically
• The 2026 developments: H200 resumption to China, the suspended Affiliates Rule, rare-earth controls
• How the aligned countries (Japan, Netherlands, UK, India, Taiwan) track the US baseline
• What Japanese companies should do, immediately and over the medium term

Background you need to read the calendar

Before the calendar, three concepts and a handful of acronyms. Skip this and the tables later will look like cipher, so bear with me.

The first concept is symmetric response: when one country imposes an export control, the other answers with a control of the same nature, licensing, item designation, or extraterritorial reach. The second is allied alignment: rather than copying the US rules verbatim, an allied country builds operations that produce an equivalent effect within its own export-control law. The third is regulatory interlocking: the quarter-by-quarter chain that runs from a BIS update to a Chinese MOFCOM announcement, to an EU delegated regulation, to a Japanese ministerial ordinance.

A few acronyms up front. BIS (the US Commerce Department's Bureau of Industry and Security) administers the Export Administration Regulations, or EAR. The Entity List is the BIS-designated list of restricted parties, exports to which require an individual license. The FDPR (Foreign Direct Product Rule) extends US controls even to foreign-made goods produced with US equipment or software. HBM (high-bandwidth memory) is stacked memory for AI compute, SME (semiconductor manufacturing equipment) is wafer-processing gear, and EDA (electronic design automation) is the software essential to chip design. On the Chinese side, MOFCOM (the Ministry of Commerce) administers export controls. You will also see IFR (interim final rule), the US format that takes effect immediately while public comment runs in parallel.

Read it as symmetric institutional response, not "conflict"

Before the year-by-year calendar, the framework that runs through the whole picture. Lay the regulations out chronologically and compare their legal structure, and you can organize the facts cleanly without a single evaluative word.

The US measures rest on four pillars: the Entity List, the FDPR, Outbound Investment screening, and the advanced-computing review policy. China's measures rest on four as well: the Dual-Use Items Export Control Regulations, Announcement No. 46 (the mineral ban), Announcement No. 61 (extraterritorial reach), and control-list designations. The names are completely different, but both share the same structure: putting specific items, specific parties, and specific conduct under a licensing requirement. In their public explanations, too, both cite national security and both build their own systems with an eye on the other side's design.

Hold that symmetry in your head while reading the calendar, and when a new rule appears you can predict "which of the other side's measures is this responding to?" When the US suspended the Affiliates Rule for a year in November 2025, it was one half of a paired trade: China suspended its rare-earth extraterritorial measure the same month. Look at only one half and the picture never resolves.

2024-2026 major regulatory schedule

Here is the main event, the single-page calendar. I divide it by year, but the essence is in the chains that cross years. As you read, notice how close the dates in the US rows and the China rows sit to each other.

2024: the third wave in earnest

When	Actor	Measure
Jan 2024	EU	Publishes the export-control white paper, declaring its own update cadence
Apr 1, 2024	UK	Export Control (Amendment) Regulations 2024 in force; quantum, semiconductors, additive manufacturing controlled as PL9013-9015
Sep 7, 2024	Netherlands	Puts two ASML DUV immersion lithography models under national license; service and parts also covered
Sep 2024	US BIS	Interim final rule (IFR) covering quantum computers, SME, advanced materials
Oct 19, 2024	China State Council	Promulgates the Dual-Use Items Export Control Regulations
Oct 28, 2024	US Treasury	Final Outbound Investment rule (restricting investment into Chinese semiconductors, quantum, AI)
Nov 15, 2024	China MOFCOM	Publishes the dual-use control list (consolidating ~700 items)
Dec 1, 2024	China	Dual-use regulations take effect
Dec 2, 2024	US BIS	Third wave on China; adds 140 entities to the Entity List; tightens HBM, SME, EDA
Dec 3, 2024	China MOFCOM	Announcement No. 46; gallium, germanium, antimony, superhard materials effectively banned for export to the US

In a span of a few days in early December, the two sides fired in sequence. BIS updated the Entity List on December 2, and the very next day, December 3, China issued Announcement No. 46 banning certain minerals to the US. The proximity of the dates is no accident; it marks the point at which both systems entered a phase of "observe the other's move, then respond at once."

2025: the AI Diffusion Rule arrives and is rescinded; the Affiliates Rule and its suspension

When	Actor	Measure
Jan 2, 2025	US	Outbound Investment Rule in force
Jan 13, 2025	US BIS	AI Diffusion Rule (IFR); classifies the world into three tiers, managing AI compute clusters and model weights
Apr 1, 2025	Netherlands	Additional ASML controls; metrology and inspection tools under national license
Apr 4, 2025	China MOFCOM	Tightens controls on seven rare earths (medium and heavy), effective the same day
May 13, 2025	US BIS	Rescinds the AI Diffusion Rule; issues three guidance documents the same day
Aug 2025	US	Conditionally licenses Nvidia H20 exports to China (15% of revenue paid to the US government)
Sep 8, 2025	EU	Adopts the 2025 dual-use list revision (delegated regulation); adds quantum, SME, additive manufacturing
Sep 23, 2025	India	SCOMET revision; creates Category 7 (emerging technologies)
Sep 29, 2025	US BIS	Affiliates Rule (50% rule) immediately effective; affiliates >50% owned by Entity List parties controlled equally
Oct 9, 2025	China MOFCOM	Announcement No. 61; extraterritorial reach for rare-earth items (license required if Chinese content >0.1%)
Nov 1, 2025	US-China	Announce the economic and trade deal, pledging mutual suspension of measures
Nov 10, 2025	US BIS	Suspends the Affiliates Rule for one year (through Nov 9, 2026); removes some Chinese firms from the Entity List
Nov 10, 2025	China	Suspends the Oct 9 extraterritorial measure through Nov 10, 2026; ban on US military end-use continues
Nov 18, 2025	Taiwan	Announces adding 18 items (advanced 3D printers, advanced semiconductor tools, quantum computers) to its strategic high-tech control list
Dec 2025	China MOFCOM	Launches a rare-earth general-license scheme; first licenses to magnet makers JL MAG, San Huan, Yunsheng
Dec 16, 2025	UK	Export Control (Amendment) No.2 Regulations 2025 in force; aligned with the EU 500 series

2025 was the year in which "building regulations" and "trading regulations" ran in parallel. In the first half, both sides traded new rules on rare earths and AI; in the second half, a new approach emerged: putting regulations on the bargaining table. The most telling moment came in November. The US suspended the Affiliates Rule (which extends controls even to affiliates more than 50% owned by Entity List parties) just six weeks after it took effect, and in exchange China suspended its rare-earth extraterritorial measure. That was the moment regulation itself became a diplomatic card.

2026: H200 resumption to China and the trading of regulations

When	Actor	Measure
Jan 15, 2026	US BIS	Shifts advanced-computing review from presumption of denial to case-by-case (Federal Register 2026-00789); covers H200, AMD MI325X, etc.
Feb 24, 2026	China MOFCOM	Designates 20 Japanese organizations on its export-control list (Mitsubishi Shipbuilding, Mitsubishi Heavy Industries, National Defense Academy, JAXA, etc.)
Apr-May 2026	China MOFCOM	April controls on seven rare earths continue; general licenses ease civilian flows, but exports run ~50% below the pre-restriction baseline
May 2026	US	Issues H200 licenses to ~10 firms including Alibaba, Tencent, ByteDance; up to ~75,000 chips each; shipments taxed
Mid-May 2026	US	Licenses issued but no actual shipments confirmed; the gap between "license" and "delivery" persists
Nov 10, 2026	US BIS	Affiliates Rule suspension expires; snaps back indefinitely absent an extension
Nov 10, 2026	China	Rare-earth extraterritorial suspension expires; decision to extend or reinstate

The biggest move of 2026 has been on AI chips. The January 15 BIS final rule (Federal Register 2026-00789) changed the review of H200 and its equivalents for China from "presumption of denial" to "case-by-case."[^1][^2] The conditions are strict: sufficient domestic US supply, no diversion of global foundry capacity, adequate security procedures on the recipient's side, and independent third-party testing in the United States.[^3]

Then in May, licenses came through for roughly ten firms, Alibaba, Tencent, ByteDance, JD, Lenovo, Foxconn, with up to about 75,000 chips each.[^4] Note carefully, though, that "a license was issued" and "the chips arrived" are two different things. As of mid-May, no actual shipments had been confirmed, and the shipments are reported to carry a tax.[^5] What looks like loosened control is, in practice, a sequence of gates that remain in place: supply verification, security requirements, and taxation. That is the signature of 2026.

China's rare earths show the same coexistence of easing and continuation. The April 2025 controls on seven medium and heavy rare earths remain in force in 2026,[^6] and exports of dysprosium and terbium are running at roughly half their pre-restriction levels.[^7] At the same time, the general-license scheme launched in December 2025 (allowing pre-cleared customers multiple shipments under a year-long permit) has partly restored civilian flows.[^8] Only the October 9 extraterritorial measure is paused; the skeleton of the regime is still standing.

A worked example: US Affiliates Rule pause ⇄ China rare-earth pause

The structure of 2026 is best captured by the paired moves of November 2025. If the previous December's "mineral ban the day after an Entity List update" was an offensive symmetric response, this is the defensive kind, both sides pulling regulations back at once.

On November 10, the US suspended the Affiliates Rule, just six weeks after it took effect, for one year.[^9] That rule pulls affiliates 50% or more owned by parties on the Entity List or Military End User List into the same controls as their parents. It imports OFAC's (the US Treasury's Office of Foreign Assets Control) 50% rule into export controls, and practitioners had warned that compliance burdens would spike.[^10] It was paused through November 9, 2026 as part of the US-China trade deal announced on November 1.[^11]

On the same November 10, China suspended its October 9 rare-earth extraterritorial measure through November 10, 2026.[^12] That measure, requiring a Chinese license for third-country transactions when Chinese content exceeds 0.1%, was a near mirror image of the Affiliates Rule. Both are moves to "pull back, for a fixed term, a regulation aimed at the other country, for the sake of a diplomatic agreement."

The thing to read here is that both suspension deadlines land on the same date: November 10, 2026. Absent an extension, the Affiliates Rule snaps back indefinitely on November 10,[^13] and China's rare-earth extraterritorial measure faces its decision the same day. In other words, November 10, 2026 is a day on which both sides' regulations could reignite simultaneously. It is worth penciling that date into your internal calendar in red.

For the full picture of critical-mineral controls, see Critical Minerals and Export Controls.

Is one of your counterparties on the Entity List or a Chinese control list? Does your rare-earth Chinese content cross a threshold? Running this kind of classification and counterparty screening by hand, quarter after quarter, is no longer realistic. TIMEWELL's TRAFEED ingests each country's primary sources and automates the screening, so you can see "the next rule that will bite" the day after it lands. If a case has you stuck, our individual consultation walks through your specific transaction patterns.

How the aligned countries (JP, NL, UK, EU, IN, TW) track the baseline

Against the US-China-EU principals, the aligned countries (Japan, the Netherlands, the UK, India, Taiwan) generally orient toward the US baseline. What they share is an operating mode: not copying the US rules, but producing an equivalent effect within their own export-control law. The EU is a principal, but at the member-state level it also behaves as an aligned actor.

Japan added 23 items in a July 2023 ordinance and another 21 across 2024 and 2025 in quantum and advanced semiconductors. The form is the Foreign Exchange and Foreign Trade Act, but the items overlap substantially with the US EAR. The Netherlands, as ASML's home, brought two DUV immersion lithography models under national control in September 2024 and metrology and inspection tools in April 2025. The EU revised its dual-use list by delegated regulation on September 8, 2025, adding quantum, SME, and additive manufacturing.

The other aligned countries are keeping pace. The UK aligned with the EU 500 series via PL9013-9015 and its December 2025 amendment; India brought SCOMET Category 7 into force in October 2025; Taiwan announced adding 18 items in November 2025. South Korea continues case-by-case operations aligned with the US baseline. The more these allied controls are built out, the more the overlap stacks up from the perspective of a third-country company. For a Japanese company, that means every additional jurisdiction multiplies, rather than adds to, the checking workload.

Impact by sector

Because regulations bite differently by sector, let me sort them into three: semiconductors, AI, and rare earths.

In semiconductors (advanced logic, memory, manufacturing equipment), the December 2024 HBM and SME tightening plus the 140-entity Entity List addition put license requirements on TSMC, Samsung, and SK hynix's China sites. The September 2025 EU 500-series revision changed operations for ASML, ASMI, ZEISS, and others. And the January 2026 BIS final rule, with its case-by-case review, is reshaping the sales channel for advanced AI chips into China.

AI (model weights, compute infrastructure) is the sector where operations have shifted most violently. The AI Diffusion Rule's publication in January 2025, its rescission in May, three guidance documents, the conditional H20 license in August (15% of revenue paid), the case-by-case final rule in January 2026, and the H200 licenses in May. In just eighteen months, the center of gravity moved from "broad management" to "case management plus trading." The current shape, licenses are granted but supply verification, security requirements, and taxation remain, is better described as a conditional restart than as deregulation.

Rare earths and critical minerals form a continuous chain: the December 2024 gallium and germanium ban on the US, the April 2025 tightening of seven medium and heavy rare earths, the October extraterritorial measure, the November pause, the December general-license launch, and the November 10, 2026 deadline. They bite directly on EV traction motors, compound semiconductors, infrared sensors, and defense and aerospace. The fact that exports remain at roughly half the pre-restriction level even with civilian flows eased by general licenses shows there is a gap between the suspension of the regime and the recovery of the reality.

A to-do list for Japanese companies

Drawing on all of the above, here are the items to tackle, immediate and medium-term. The order matters, so work down from the top.

For the immediate term, start with a Chinese-content inventory. Announcement No. 61's 0.1% rule is paused, but an extension beyond November 10, 2026 is not guaranteed, so check rare-earth content across all products now. Next, re-verify end users: check each quarter whether your counterparties have landed on a Chinese control or watch list. Then document your triple compliance: prepare paperwork on the assumption that Japan's FEFTA, the US EAR, and China's dual-use regulations all apply to the same transaction at once.

For the medium term, begin with alternative sourcing. Evaluate non-Chinese sources, Australia, India, Canada, for rare earths, gallium, and germanium. For AI-chip procurement planning, track the license history of counterparties that can handle the US case-by-case review. As the H200 case shows, even an approved license can take time to turn into a shipment, so build in longer procurement lead times. Finally, your compliance structure: set up the two-tier model the METI guidelines describe, a management committee plus a dedicated working unit, so your first response is fast when the regulations reignite.

Common misconceptions / FAQ

Q1. If the H200 is approved, has China-bound AI-chip control loosened?

A. Not exactly. Licenses for about ten firms came through in May 2026, but several gates remain: US domestic supply verification, third-party testing, security requirements, and a tax on shipment. As of mid-May, no actual shipments were confirmed, and the gap between license and delivery persists. Most advanced chips such as Blackwell remain under control.

Q2. Does China's 0.1% rule really bite Japanese companies?

A. Under Announcement No. 61, yes. If a piece of equipment worth a million dollars contains a thousand dollars' worth of Chinese rare earths, exporting it to a third country requires a Chinese MOFCOM license. It has been paused since November 2025, but the pause expires on November 10, 2026, and an extension is not confirmed.

Q3. Where should a beginner start?

A. Three steps, in order. First, confirm your product's classification (HS code, ECCN, Chinese dual-use list number). Second, check key counterparties against the Entity List and the Unreliable Entity List. Third, survey Chinese content (rare earths, specific materials). These three reveal 80% of the picture.

Wrapping up

• From 2024 to 2026, the regulations repeat a chain roughly every quarter: one country's measure, another's symmetric response, the allies' alignment
• Both offensive symmetric responses (the December 2024 mineral ban the day after the Entity List addition) and defensive ones (the November 2025 Affiliates Rule pause paired with the rare-earth pause) appear
• 2026 is defined by the H200's conditional restart to China, where licenses are granted but supply, security, and tax gates remain, a "conditional restart"
• The allies (JP, NL, UK, EU, IN, TW) do not copy US rules; they produce an equivalent effect within their own law
• Japanese companies must run their immediate and medium-term to-dos in parallel, on the assumption of triple compliance under FEFTA, the US EAR, and China's dual-use regulations

The next major fork is November 10, 2026. The Affiliates Rule's snap-back and China's rare-earth decision land on the same day, and whether regulation reignites or the deal is extended will turn on it. Simulate now "which of our transactions would stop if it reignites," and you will not be caught flat-footed on the day.

Related articles

If you want to follow the interlocking structure more deeply, these are worth reading alongside this one.

• Critical Minerals and Export Controls
• China's February 2026 Export-Control Listing of Japanese Organizations
• The US Affiliate Rule (50% Rule): November 2026 Guide
• EU Export Regulation: 2026 Edition
• EAR Affiliate Rule and Third-Country Subsidiary Risk
• Japan Export Control: Spring 2026 Update
• Global Export Regulation: 2026 Edition

If you can't track the interlock every day

This article alone brought up more than 90 dates and over 60 rule and organization names. Is it realistic to keep up, every day, with quarterly updates across the US, China, the EU, Japan, the Netherlands, the UK, India, and Taiwan using only your own general affairs and legal teams? The primary sources span English, Chinese, and Japanese, and a single miss can leave you in a state where "by the next day, your own company is the regulated party."

TIMEWELL's TRAFEED (formerly ZEROCK ExCHECK), the world's first export-control AI agent, continuously ingests each country's primary sources, the Federal Register, MOFCOM announcements, official gazettes, EU delegated regulations, and automates impact analysis against your own transaction patterns. It processes multilingual primary sources directly, cross-checks the Entity List, control lists, and watch lists, and screens against METI standards, the US EAR, and China's dual-use regulations at once. When a rule changes, an alert fires.

Build the capability to know "which regulation will hit us next" the day after it lands. If a classification or counterparty-screening case has you stuck, let's talk it through first.

→ TRAFEED individual consultation (30 min)

TRAFEED service details

Footnotes

[^1]: Federal Register, "Revision to License Review Policy for Advanced Computing Commodities" (2026-00789), effective Jan 15, 2026. https://www.federalregister.gov/documents/2026/01/15/2026-00789/revision-to-license-review-policy-for-advanced-computing-commodities [^2]: BIS, "Department of Commerce Revises License Review Policy for Semiconductors Exported to China." https://www.bis.gov/press-release/department-commerce-revises-license-review-policy-semiconductors-exported-china [^3]: Covington & Burling LLP, "U.S. Commerce Department Revises License Review Policy for Exports of Certain Advanced Computing Commodities to China and Macau," Jan 2026. https://www.cov.com/en/news-and-insights/insights/2026/01/us-commerce-department-revises-license-review-policy-for-exports-of-certain-advanced-computing-commodities-to-china-and-macau [^4]: Tom's Hardware, "The Nvidia H200 export saga, as it happened." https://www.tomshardware.com/tech-industry/semiconductors/us-eases-nvidia-export-restrictions-h200-cleared-for-china-under-tight-controls [^5]: Tom's Hardware, "Nvidia prepares shipment of 82,000 AI GPUs to China as chip war lines blur." https://www.tomshardware.com/tech-industry/semiconductors/nvidia-prepares-h200-shipments-to-china-as-chip-war-lines-blur [^6]: Taylor Wessing, "Key Changes in China's Export Control Landscape for Rare Earths," Apr 2026. https://www.taylorwessing.com/en/insights-and-events/insights/2026/04/key-changes-in-china-s-export-control-landscape-for-rare-earths [^7]: China Briefing, "China's Rare Earth Export Controls - Impact on Businesses and Industries." https://www.china-briefing.com/news/chinas-rare-earth-export-controls-impacts-on-businesses/ [^8]: China Briefing, same source (general-license scheme and licenses to JL MAG and others). https://www.china-briefing.com/news/chinas-rare-earth-export-controls-impacts-on-businesses/ [^9]: DLA Piper, "US trade deal with China update: The BIS suspended the 50-percent ownership rule," Nov 2025. https://www.dlapiper.com/en-us/insights/publications/2025/11/bis-to-suspend-50-percent-ownership-rule [^10]: Federal Register, "Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities" (2025-19001), effective Sep 29, 2025. https://www.federalregister.gov/documents/2025/09/30/2025-19001/expansion-of-end-user-controls-to-cover-affiliates-of-certain-listed-entities [^11]: Skadden, "BIS Suspends Affiliates Rule for One Year as Part of the US-China Trade Deal," Nov 2025. https://www.skadden.com/insights/publications/2025/11/bis-suspends-affiliates-rule-for-one-year-as-part-of-the-us-china-trade-deal [^12]: Clark Hill PLC, "China Hits 'Pause' on Rare-Earth Export Controls and What it Means for Supply Chains." https://www.clarkhill.com/news-events/news/china-hits-pause-on-rare-earth-export-controls-and-what-it-means-for-supply-chains/ [^13]: Arnold & Porter, "U.S. Department of Commerce Officially Suspends Enforcement of the Affiliates Rule for One Year," Nov 2025. https://www.arnoldporter.com/en/perspectives/blogs/enforcement-edge/2025/11/doc-suspends-enforcement-of-the-affiliates-rule-for-one-year

References

• US: BIS (bis.gov), Federal Register (federalregister.gov), US Treasury Outbound Investment, CRS R48642
• China: MOFCOM (mofcom.gov.cn), Dual-Use Items Export Control Regulations, Announcements No. 46 and No. 61
• EU/UK: EU Trade and Economic Security, EU 2024 White Paper on Export Controls, UK ECJU notices
• Japan: METI Security Export Control, CISTEC, JETRO
• Industry/law firms: CSIS, Covington, Skadden, DLA Piper, Arnold & Porter, Taylor Wessing, Tom's Hardware