# Nvidia chips and China: where the export rules stand, with a dated timeline

By Spezia. Published November 10, 2026. Updated November 10, 2026. Data as of November 10, 2026.
Canonical page: https://spezia.ai/blog/nvidia-china-chip-export-rules

## The short answer

Since January 15, 2026, U.S. rules let Nvidia apply for licenses to sell H200-class chips to China, reviewed case by case, and, according to Nvidia, a 25% import duty applies to those chips when they enter the United States for inspection. Nvidia says it has shipped a fraction of what its licenses allow, and that the Chinese government restricted the sales. Reuters reports about 600,000 H200 chips are waiting in Hong Kong for Chinese approval.

- A January 2026 rule moved H200-class chips from presumed denial to case-by-case license review, with conditions on volume and testing.
- Nvidia describes the 25% charge as a tariff on importation, set by a January 2026 proclamation. Spezia found no government page that calls it a license fee or a revenue share.
- Nvidia's quarterly report says it was effectively foreclosed from China's data center market, and that H200 shipments were under 1% of its data center revenue.
- Spezia found no published Chinese rule. Reuters reports, from anonymous sources, that about 600,000 H200 chips sit in Hong Kong without approval for mainland import.
- Several stories this week rest on anonymous sources or a single outlet, and this page marks which.
- Spezia found no chip export bill that has become law, and the final contents of the 2027 defense bill are open.

## What are the U.S. rules for selling AI chips to China now?

The operative rule is a Commerce Department rule that took effect on January 15, 2026. It moved chips such as Nvidia's H200 and AMD's MI325X from a presumption of denial to case-by-case review of license applications for customers in China and Macau.

The rule sets conditions. The applicant must show there is enough supply for U.S. customers. Volume to China and Macau may not exceed 50% of the total processing performance shipped to customers in the United States. The buyer must describe its security and customer-vetting controls, and every shipment must be reviewed by a qualified third-party testing lab with a U.S. address, which may test a sample of each batch. Customers headquartered in Macau or in the other restricted country group stay under presumed denial.

The chips covered are those below set limits on processing performance and memory bandwidth. Reuters reported in December that President Trump said Blackwell and Rubin chips were not part of the arrangement.

## What is the 25% charge?

Nvidia describes it as an import duty. Proclamation 11002, signed January 14, 2026, sets a 25% duty on certain advanced computing chips entering the United States on or after January 15. It lists exemptions, including U.S. data centers, research and development, and startups.

The proclamation does not name the H200 or China. The link comes from Nvidia's own report. It says the licenses require H200 chips to pass an inspection in the United States before shipping, so they are subject to the 25% duty when imported, and that Nvidia has been unable to pass any of the duty on to customers. Spezia found no government page that calls it a license fee or a share of revenue.

## What happened, in order?

| Date | What happened | Source and status |
| --- | --- | --- |
| October 2022 | First published rule setting controls on advanced chips to China, with most license applications presumed denied. Nvidia says license requirements had been announced to it in August 2022 | Federal Register, 87 FR 62186 |
| October 2023 | Controls tightened and re-based on total processing performance | Federal Register, 88 FR 73458 |
| April 9, 2025 | The government told Nvidia it needs a license to export H20 chips to China. Nvidia booked a $4.5 billion charge in the quarter that ended April 27, 2025 | Nvidia filings |
| July 14, 2025 | Nvidia said the government had assured it licenses would be granted | Nvidia blog |
| August 2025 | H20 licenses granted. Nvidia says officials expected the government to receive 15% of revenue, with no regulation published | Nvidia quarterly report |
| December 8, 2025 | President Trump said H200 sales to approved customers would be allowed, with 25% going to the United States | Reuters, as reported |
| January 13 to 15, 2026 | Commerce publishes the case-by-case rule | Federal Register, 91 FR 1684 |
| January 14, 2026 | Proclamation sets the 25% import duty | Federal Register, 91 FR 2443 |
| January 2026 | Reuters reports, from anonymous sources, that Chinese customs were told H200 chips are not permitted, then that three large companies were approved for more than 400,000 chips in total | Reuters, as reported |
| February 2026 on | U.S. licenses allow small shipments to specific Chinese customers. Nvidia says the Chinese government restricted the sales | Nvidia quarterly report |
| May 20, 2026 | Nvidia reports no revenue yet under the H200 licensing program | Nvidia quarterly report |
| August 26, 2026 | Nvidia says it was effectively foreclosed from China's data center market | Nvidia quarterly report |
| November 5, 2026 | Reuters reports about 600,000 H200 chips stored in Hong Kong | Reuters, as reported |
| November 8, 2026 | Nvidia's board announces an independent investigation | Nvidia statement |

## What does Nvidia say about China?

In its report for the quarter ended July 26, 2026, filed August 26, Nvidia says that under current rules it cannot create a competitive product for China's data center market that both the U.S. and Chinese governments approve. It says it is effectively foreclosed from competing in that market. It also says it has shipped a fraction of the volume its H200 licenses allow, and that those shipments were under 1% of its data center revenue in the quarter.

It took a $0.4 billion charge in the first half of its fiscal year for H200 inventory as demand diminished. Its outlook assumes no data center compute revenue from China.

Revenue from customers headquartered in China, including Hong Kong, is larger because it covers all products, such as the gaming and workstation GPUs Nvidia says it can ship there. It is counted by the customer's headquarters, not by where products ship, and it is not a measure of H200 sales.

| Quarter | China, including Hong Kong | Total | Share of total |
| --- | ---: | ---: | ---: |
| Second quarter, to July 26, 2026 | $7.88 billion | $96.2 billion | 8.2% |
| First quarter, to April 26, 2026 | $4.55 billion | $81.6 billion | 5.6% |

Nvidia changed the basis on which it reports geography, so these figures cannot be compared with its filings from a year earlier. The shares are Spezia's division.

## What is China doing?

Beijing has not published a rule that Spezia could find. What exists is reporting and Nvidia's own description. Reuters reported on November 5, citing two people, that about 600,000 H200 chips are stored in Hong Kong awaiting shipment to mainland China. It said, citing other people, that Beijing has yet to approve large-volume imports, and that one source said several major Chinese internet companies had received about 10,000 chips each.

Nvidia's report says the Chinese government has encouraged customers to buy from China-based competitors, and has discouraged purchases of Nvidia's data center products.

On November 9, a spokesperson for China's foreign ministry was asked about the Reuters report. The ministry said its position on U.S. chip exports to China is consistent and referred specific questions to competent authorities.

The January 28 Reuters report that China approved three companies for more than 400,000 chips in total is a separate, earlier story. The November report names no companies for the 10,000 figure.

## What else was reported this week?

The first two items rest on anonymous sources or a single outlet. The third rests on Nvidia's own statement.

- **A limit on China exposure.** The Financial Times reported on November 2 or 3, citing five people, that Nvidia told cloud customers to sell at least 51% of their services to non-Chinese companies on new contracts. Nvidia neither confirmed nor denied it. China's foreign ministry said it was not familiar with the specifics.
- **Moonshot AI.** CNBC reported on November 5, from anonymous sources, that the Chinese lab sought Blackwell capacity at European data centers. The talks were not described as a signed deal.
- **The Nvidia board.** Nvidia's board said on November 8 that it opened an independent investigation, overseen by independent directors, in light of reports that its chief executive was the target of a foreign intelligence effort. The board said it has no reason to believe national security or Nvidia secrets were compromised. China's foreign ministry called the allegation unsubstantiated. Three House committee chairs asked for a closed-door briefing on November 18. No charges have been reported.

## What is pending in Congress?

Spezia found no chip export bill that has become law. The Chip Security Act, which would require location verification on covered chips, was marked up by the House Foreign Affairs Committee on March 26, 2026. The GAIN AI Act, which would put U.S. customers first, passed the Senate as an amendment to the 2026 defense bill, and Nextgov reported in December, citing two people, that it was not expected in the final text. The Senate version of the 2027 defense bill includes the AI OVERWATCH Act, a chip export measure, according to its sponsor's office. Spezia could not confirm what the final bill will contain.

## How do you read a chip export headline?

Six checks help.

1. **Rule or announcement?** A statement of intent is not a published rule. Look for a Federal Register citation.
2. **License or shipment?** A license allows a sale. It does not mean the sale happened.
3. **Whose approval?** Both governments must approve, and each can stop a sale.
4. **Which chip?** H20, H200 and Blackwell are different tiers with different rules.
5. **Which revenue?** China revenue covers many products and is not data center sales.
6. **How many sources?** One anonymous source is a lead, not a finding.

Open AI Intel to read the policy and geopolitics desks, one line per event, with the source and a label for fact, claim or speculation. Ask Spezia how a rule affects your plans. [Follow policy and geopolitics](https://spezia.ai/tools/ai-intel)

## How this was made

Rules are read from the Federal Register and the Bureau of Industry and Security. Company statements are read from Nvidia's filings and releases. Chinese statements are read from the foreign ministry's own press transcripts. Reports from Reuters, the Financial Times, CNBC and others are labeled as reports, with what they rest on. The date of each item is shown, and conflicts between sources are noted.

## Frequently asked questions

### Can Nvidia sell H200 chips to China?

Yes, with a U.S. license. Since January 15, 2026, applications for H200-class chips are reviewed case by case. Nvidia says it has shipped a fraction of what its licenses allow and that the Chinese government restricted the sales, and its outlook assumes no China data center revenue.

### What is the 25% on Nvidia H200 chips sold to China?

A U.S. import duty. Proclamation 11002 sets a 25% duty on certain advanced chips entering the country. Nvidia says H200s bound for China must be inspected in the United States first, so the duty applies, and that it has not been able to pass it on.

### How much of Nvidia's revenue comes from customers headquartered in China?

Customers headquartered in China, including Hong Kong, were $7.88 billion of $96.2 billion in revenue in the quarter to July 26, 2026, about 8.2%. That covers all products. Nvidia says H200 data center shipments were under 1% of its data center revenue.

### Has China approved Nvidia H200 imports?

China has announced no rule that Spezia could find. Reuters reports, from anonymous sources, that Beijing has not approved large-volume imports, and Nvidia says the Chinese government restricted sales. China's foreign ministry says its position is consistent.

### How many Nvidia H200 chips are stored in Hong Kong?

About 600,000, according to Reuters on November 5, 2026, citing two people familiar with the matter. It is an unconfirmed estimate. Nvidia and two Chinese agencies, the industry ministry and the planning commission, did not respond to Reuters.

### Did the Nvidia board find anything in its investigation?

Not yet. The board announced the investigation on November 8, 2026, and said it has no reason to believe national security or Nvidia secrets were compromised. It will examine all available information. No results or charges have been reported.

## Sources

1. [Department of Commerce revises license review policy for semiconductors exported to China](https://bis.gov/press-release/department-commerce-revises-license-review-policy-semiconductors-exported-china), Bureau of Industry and Security
2. [Revision to license review policy for advanced computing commodities, 91 FR 1684](https://www.govinfo.gov/content/pkg/FR-2026-01-15/html/2026-00789.htm), Federal Register
3. [Adjusting imports of semiconductors, Proclamation 11002, 91 FR 2443](https://www.govinfo.gov/content/pkg/FR-2026-01-20/html/2026-01052.htm), Federal Register
4. [Implementation of additional export controls, 87 FR 62186](https://www.govinfo.gov/content/pkg/FR-2022-10-13/html/2022-21658.htm), Federal Register
5. [Implementation of additional export controls: updates and corrections, 88 FR 73458](https://www.govinfo.gov/content/pkg/FR-2023-10-25/html/2023-23055.htm), Federal Register
6. [NVIDIA Corp, Form 8-K, April 2025](https://www.sec.gov/Archives/edgar/data/1045810/000104581025000082/nvda-20250409.htm), U.S. Securities and Exchange Commission
7. [NVIDIA Corp, Form 10-Q for the quarter ended July 26, 2026](https://www.sec.gov/Archives/edgar/data/1045810/000104581026000075/nvda-20260726.htm), U.S. Securities and Exchange Commission
8. [NVIDIA announces financial results for the second quarter of fiscal 2027](https://nvidianews.nvidia.com/news/nvidia-announces-financial-results-for-second-quarter-fiscal-2027), NVIDIA
9. [NVIDIA Corp, Form 10-Q for the quarter ended July 27, 2025](https://www.sec.gov/Archives/edgar/data/1045810/000104581025000209/nvda-20250727.htm), U.S. Securities and Exchange Commission
10. [NVIDIA Corp, Form 10-Q for the quarter ended April 26, 2026](https://www.sec.gov/Archives/edgar/data/1045810/000104581026000052/nvda-20260426.htm), U.S. Securities and Exchange Commission
11. [NVIDIA CEO promotes AI in Washington and China](https://blogs.nvidia.com/blog/nvidia-ceo-promotes-ai-in-dc-and-china/), NVIDIA
12. [US to allow Nvidia H200 chip shipments to China, Trump says](https://www.thestandard.com.hk/innovation/article/318810/US-to-allow-Nvidia-H200-chip-shipments-to-China-Trump-says), Reuters, via The Standard
13. [Foreign ministry spokesperson's regular press conference, November 3, 2026](https://www.fmprc.gov.cn/eng/xw/fyrbt/lxjzh/202611/t20261103_12052547.html), Ministry of Foreign Affairs of China
14. [Chairman Mast: HFAC advances the Chip Security Act](https://foreignaffairs.house.gov/news/press-releases/chairman-mast-hfac-advances-chip-security-act), House Foreign Affairs Committee
15. [Banks secures AI OVERWATCH Act in Senate NDAA](https://www.banks.senate.gov/news/press-releases/banks-secures-ai-overwatch-act-in-senate-ndaa/), Office of Senator Banks
16. [Statement from NVIDIA Board of Directors](https://investor.nvidia.com/news/press-release-details/2026/Statement-from-NVIDIA-Board-of-Directors/), NVIDIA
17. [Foreign ministry spokesperson's regular press conference, November 9, 2026](https://www.fmprc.gov.cn/eng/xw/fyrbt/lxjzh/202611/t20261109_12056171.html), Ministry of Foreign Affairs of China
18. [Nvidia chips pile up in Hong Kong as China withholds import approval](https://www.thestandard.com.hk/innovation/article/347673/Nvidia-chips-pile-up-in-Hong-Kong-as-China-withholds-import-approval), Reuters, via The Standard
19. [House committee chairs' request for a briefing, November 5, 2026](https://foreignaffairs.house.gov/news/press-releases/chairmen-mast-moolenaar-and-crawford-request-jensen-huang-brief-congress-on-link-to-chinese-intelligence-asset), House Foreign Affairs Committee
20. [Bill prioritizing American customers for AI chips not expected to make it into final NDAA](https://www.nextgov.com/policy/2025/12/bill-prioritizing-american-customers-for-ai-chips-not-expected-make-it-final-ndaa-sources-say/409920/), Nextgov/FCW

## Cite this

Spezia. "Nvidia chips and China: where the export rules stand, with a dated timeline" Spezia, November 10, 2026. https://spezia.ai/blog/nvidia-china-chip-export-rules