NVIDIA faces significant challenges due to new export regulations by the United States. These regulations not only affect custom chips like the A800 and H800 but also impact consumer-grade graphics cards like the RTX 4090. In this article, we explore the specifics of the new regulations, how they differ from previous ones, and the implications for NVIDIA and the technology industry.

Previous Export Regulations

Before the new licensing rules, U.S. export restrictions focused on the on-device connection speed. NVIDIA adapted to these regulations by developing custom products based on Ampere and Hopper architectures, namely the A100 and H100 series. These products were initially designed to comply with the previous set of U.S. export regulations.

The New U.S. Export Licensing Rules

On October 17, 2023, the U.S. Government announced a shift in the criteria for export restrictions, moving from connection speed to performance thresholds. The newly introduced Interim Final Rule specifically amends Export Control Classification Numbers (ECCN) 3A090 and 4A090, affecting the export of certain NVIDIA integrated circuits to several countries, most notably China.

Regulatory Details: The Interim Final Rule

The Interim Final Rule imposes additional licensing requirements for exporting to China and other Country Groups like D1, D4, and D5. The restrictions encompass not just chips but also any system incorporating one or more of the specified integrated circuits. This means that even NVIDIA DGX and HGX systems fall under the new export control purview.

Implications for NVIDIA

NVIDIA faces a two-fold challenge. First, there is a considerable number of companies in China involved in the final packaging of consumer-grade RTX 4090 series graphics cards. Second, many board partners operate exclusively in China. The new licensing requirements make it difficult for NVIDIA to engage in these critical aspects of their supply chain.

Impact on Industry and Geopolitics

These new regulations aim to limit China’s capacity to advance its technologies, particularly in military applications. It closes loopholes that previously allowed the export of such chips to embargoed regions within China, thereby affecting not just NVIDIA but potentially other players in the technology industry.

Short Window for Adaptation

NVIDIA has a limited period, precisely 29 days from the announcement of the Interim Final Rule, to adapt to these new restrictions. Failure to comply could result in substantial disruptions to their supply chain and sales operations.

Final Thoughts

The newly imposed export regulations on NVIDIA present a complex set of challenges that extend beyond the company to the broader tech industry. While the focus is to limit China’s technological advancement, particularly in military applications, the repercussions could ripple across multiple sectors, impacting both hardware manufacturers and consumers.

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