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China Semi Sector – 2022 Sanctions – Part 1

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Recent news coverage in western media suggests that US sanctions against China’s semiconductor sector have caught the CCP and mainland industry leaders off guard. In this research article, we examine this issue in the context of the global supply chain to analyze the short-term and long-term impact of US sanctions and the implications for both China and key industry players.
SINOLOGIX Staff
www.sinologix.io
info@sinologix.io
2022-10-20
China Semi Sector - Part 1 - Executive Summary

Executive Summary

Background

Contrary to reports in western media, the latest US sanctions came as no surprise to the CCP or China’s semiconductor sector. As early as March 13, 2021, China had already incorporated semiconductor manufacturing self-sufficiency into its 14th Five-Year Plan.

Advanced manufacturing of semiconductor wafers below the 10nm threshold and support for third-generation semiconductor materials is a critical enabling technology for AI, high-speed computing, 5G, and the EV and renewable energy sectors. The US has become increasingly concerned that China’s access to advanced semiconductor manufacturing, whether acquired from foreign suppliers or home-grown, will enable it to maintain parity with the US in military and industrial applications.

Sanctions against China have been gradually tightened over the last several years. In September 2020, the Trump administration imposed significant limits on technology that could be sold to SMIC, China’s most advanced chip-maker. On October 7, 2022, the US Commerce Department’s Bureau of Industry and Sanctions (“BIS”) imposed much stricter limits on US companies selling semiconductor manufacturing equipment and other technologies and services to Chinese chip and digital product manufacturers.

Long-term Impact Unknown

While these sanctions will have a very real near-term impact on China’s ability to produce advanced chips, the long-term impact is a much more nuanced question:

While 10nm or less chips are critical for advanced computing applications, the bulk of the Chinese market still relies on older chip technology – much of China’s economic engine is sustainable using still available technologies.

But the real question is whether or not China has already acquired enough technical expertise that it will be able to bootstrap its domestic chip sector and compete in global markets, as well as supply adjacent sectors, including the military, with the above-mentioned enabling technologies for AI and super-computing.

Unintended Consequences

As with the far-reaching sanctions against Russia for its invasion of Ukraine, the sanctions against China’s semiconductor sector may have unintended consequences:

First, US chip, EDA, and fab equipment suppliers have had tightly integrated relationships with China, which is the world’s largest consumer of chip technologies. Closing access to Chinese markets will have a ricochet effect on US chip company revenues.

Second, sanctions will trigger an even more focused effort on the part of the CCP to implement the innovation objectives outlined in the 14th Five-Year Plan. While China is still years behind the US in core chip technologies, it can be argued that the CCP’s ability to execute comprehensive, long-term strategies offsets to some degree the near-term repercussions of sanctions.

2 Part Series

In this Part 1 of our two-part series on China’s semiconductor sector, we examine the intertwined global value chain in the semiconductor sector, details of the sanctions, as well as the US’ objectives with respect to choking off competition from China. Finally, we offer a preliminary assessment of the implications for both China and several international market participants.

In Part 2, we will examine the Chinese government’s strategic plans to decouple China’s reliance on western technologies and suppliers.

Semiconductor Sector – A Quick Primer

Overview

China is both a consumer and producer of semiconductor components and end-user products. To better understand the impact of sanctions, both in terms of the intended impact on China as well as the unintended impact on global markets, it’s worth reviewing the overall structure of the semiconductor sector, as well as some specifics regarding the mainland Chinese market.

Value Chain

The semiconductor industry has evolved into a specialized ecosystem that optimizes every step of the value chain:

Fabless companies design chips and other hardware devices but outsource actual manufacturing to third-party foundries (fabs). Since fabless companies are not burdened by the capital and time investment for manufacturing processes, they can be much more adaptive to market demands.

Dedicated (or Pure Play) Semiconductor Foundries focus on manufacturing wafers and chips designed by fabless manufacturers. Foundries do not sell finished chips, so they don’t compete with fabless designers. Due to the extraordinary capital and time required to build foundries, this sub-sector has consolidated around several dominant participants, of which Taiwan Semiconductor Manufacturing Company (TSMC) is the largest.

Outsourced Semiconductor Assembly and Testing (OSAT) companies provide back-end services to foundries – they focus on packaging and testing.

Integrated Device Manufacturers (IDM) companies handle the end-to-end chip design – manufacture – assembly – test life cycle. Intel and Samsung are the world’s two largest IDMs. But in the complex chip ecosystem, they also work with and participate as, fabless designers and foundries.

Semiconductor Sector Value Chain
Image - SINOLOGIX
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Third-Party Suppliers

In addition to the fabless – foundry – OSAT value chain, there are two important third-party suppliers:

Electronic Design Automation (EDA or ECAD) software enables fabless designers to efficiently develop extremely complex chips that can have billions of components – EDA software automates design, simulation, analysis and verification, manufacturing preparation, and functional safety. Synopsis and Cadence are two of the largest EDA vendors.

Lithography – Deep Ultraviolet (DUV) and Extreme Ultraviolet (EUV) Lithography Equipment manufacturers provide highly specialized equipment used by foundries and IDM’s to etch IC designs into chip wafers – these tools are so complex and proprietary that even multi-billion dollar foundries use third-party equipment. ASML is the leading EUV vendor with a near-monopoly on the most advanced sub-10nm lithography tools.

NOTE – the above Industry Leaders chart excludes ASML and TSMC. 

China Semiconductor Sector

As of 2020, China was the world’s largest market for semiconductors, with $239.5B, or 53.7%, of the $446.1B global chip market. But $199.7, or 83.38%, of that, was imported from multinational suppliers, meaning China has had a paltry 16.62% self-sufficiency rate.

Furthermore, numerous foreign semiconductor companies operate fabrication plants and design facilities in China, including SK Hynix, TSMC, Samsung, UMC, Texas Instruments, Micron, and until 2021, Intel. So, of the $39.9B of domestic production, only $2.63, or 6.6%, was produced by mainland-headquartered chip manufacturers.

Semiconductor Sector - Global Sales - $B (2012 - 2029)

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Semiconductor Sector - Global Sales (2012 - 2029)

Data Source – Statista

Semiconductor Sector - Global Leaders - $B (2022)

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Semiconductor Sector - Global Leaders - $B (2022)

Data Source – Statista

Sanctions

Overview

The US Commerce Department’s Bureau of Industry and Commerce (BIS) published Rule 87 FR 62186 on October 7, 2022, which amended previously issued Export Administration Regulations (EAR or sanctions) that govern technologies and services that can be provided to companies on what is known as the BIS “Entity List”, which is simply a list of sanctioned companies. The amended EAR will:

Implement necessary controls on advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items.
Expand controls on transactions involving items for supercomputer and semiconductor manufacturing end uses. For example, this rule expands the scope of foreign-produced items subject to license requirements for 28 existing entities on the Entity List that are located in China.
Limit activities of “US persons” that “support” the “development” or “production” of certain ICs in the PRC – these individuals will require a special license.

The penalties for violating the sanctions/EAR are substantial – the greater of $250K or twice the amount of the offending transaction.

Scope of Sanctions

The updated EAR specifies the following technologies:

Certain advanced and high-performance computing chips.
Domestic and foreign-produced items used for supercomputers.
Logic chips with non-planar transistor architectures of 16nm or 14nm, or less.
DRAM memory chips of 18nm half-pitch or less.
NAND flash memory chips with 128 layers or more.
Certain semiconductor manufacturing equipment (see below).

What Are the Real Objectives?

As discussed in Gregory Allen’s assessment of the updated EARS, published by the Center for Strategic and International Studies, the US government is trying to close loopholes from previous measures using a four-pronged approach to close so-called technology choke points.

Advanced Chips for AI and Supercomputing

Chinese AI and supercomputing initiatives have been cut-off from advanced GPU chips that are mostly of US origin (e.g. NVIDIA and AMD). Since advanced chips are perceived to be critical to China’s AI and supercomputing programs, the objective is to force these programs to shut down or be significantly curtailed. “Advanced” is defined as supporting more than 300 teraflops (300 trillion floating point operations per second) and an interconnect speed of more than 600 GB/second (i.e. the data transfer rate between multiple GPU/CPU’s).

Electronic Design Automation (EDA) Software

Modern chips contain billions of transistors and are far too complicated to design without the use of EDA, which, as noted above, is a specialized CAD tool used by the semiconductor industry. Of the three market leaders, Cadence Design and Synopsis are US-headquartered, while Mentor Graphics was founded in the US, but has since been acquired by Siemens.

The second leg of the updated EAR prohibits the sale of EDA software to Chinese fabless companies – and without EDA, they will be challenged to continue designing advanced chips.

But even if Chinese fabless companies manage to acquire EDA software, the updated EAR will block their ability to manufacture chips designed using illegally-acquired EDA outside of China – and with the exception of recent developments by SMIC, domestic Chinese companies lack the ability to manufacture advanced chips.

Advanced Chip Manufacturing Equipment

China will no doubt endeavor to compensate for constraints on access to international foundries. In the absence of any other sanctions, it would simply purchase the DUV and EUV lithography equipment necessary for domestic fabs to produce advanced chips.

The third aspect of the updated EAR is a restriction on sales of lithography equipment needed to manufacture advanced chips. To further hamstring efforts to use previously purchased equipment, the updated EAR also prohibits sales of support services need to configure and maintain high-end lithography equipment.

Components

Even if the restrictions listed above successfully shut down the semiconductor industry in China, it would still be possible for China to effectively reinvent the wheel and recreate an entire industry from the ground up. But to accomplish that, it would need sub-components sourced from the US and other multi-nationals.

Therefore, the final leg of the updated EAR prohibits component sales to Chinese companies.

BIS Entity List

The BIS Entity List consists of named foreign businesses, research organizations, government organizations and other entities that are subject to the new (and previously issued) EAR. Nominally, the sanctions are intended to regulate dual-use items (those that can be used for commercial or civil use but can also be used for terrorism, military, or weapons of mass destruction applications) – these parties cannot purchase the covered technologies and services. But in this case, they’re intended to also handicap commercial advantages that accrue from access to the sanctioned technologies.

BIS also maintains an Unverified List of entities whose “bona fides” have not been validated (i.e. BIS has not certified that they are in compliance with the EAR and may be suspected of illegally using sanctioned products and services. In effect, these entities are limited by a “presumption of denial”, as if they’re already on the Entity List.

SINOLOGIX Analysis

Overview

On paper, China has huge exposure to the latest sanctions imposed by the US – the underlying assumption is these sanctions will have an asymmetrical impact on China. However, in a global economy, it is extremely difficult, if not impossible, to implement economic sanctions that unilaterally affect one party without attendant repercussions on all parties in the value chain – the sanctions imposed on Russia after it invaded Ukraine in 2022 are a textbook example of the unintended consequences of foreign policy and sanctions implemented in the framework of a global economy – not only has Russia been able to pivot to Central and East Asian markets to sell its oil, natural gas, and coal, but EU markets have been deprived of those same commodities to sustain their respective economies.

 We believe a comparable outcome is likely with the sanctions imposed against the Chinese semiconductor sector. Although TSMC and ASML are neither US nor China-based, they are the two most important third-party suppliers in the value chain and any disruption to their revenue or operations is likely to ripple downstream to other market participants. 

Semiconductor Exports to China

The global market for all semiconductors is expected to grow from $595B in 2021 to more than $1.2T in 2030. China is the world’s largest consumer (not producer) of semiconductor chips by far, accounting for 40% of global demand. Until the latest sanctions in October 2022, the mainland China market has accounted for 30% of US chip sales, 20% of ASML’s revenues and is the largest market for South Korean semiconductor manufacturers.

Note – in the two charts below, only a portion of the revenue shown is impacted by the October 2022 sanctions.

US Semiconductor Sales to China – $M (2022)

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US Semi Sales to China – $M (2022)

Data Source – Light Reading

US Semiconductor Sales to China – $M (2022)

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US Semi Sales to China – $M (2022)

Data Source – Light Reading

Possible Outcomes

Low-Process vs Advanced Chips

In any analysis of sanctions against China’s domestic semiconductor market, it’s important to differentiate between the advanced sub-10nm chips used for AI, supercomputing, and military applications vs. low-process chips used for PC, smartphones, and other consumer products.

While the latest sanctions related to advanced chip technology have captured headlines, the overwhelming majority of chips currently produced (90%) are low-process 28nm+ models. And this trend will continue for the foreseeable future.

The bulk of China’s semiconductor requirements are 28nm+ chips – therefore, current sanctions are unlikely to have any material effect on China’s role as a consumer.

Self-Sufficiency

As noted above, although China consumed $238B worth of semiconductors in 2021, $198.5B, or 83.4%, of all chips sold in China were imported from multinational suppliers, meaning China has had a paltry 16.62% self-sufficiency rate.

Given the impact of progressively tighter restrictions on advanced chips and related lithography equipment, China has already invested more than $150B (or more) to improve its self-sufficiency rate for 28nm chips. The “Made in China” initiative has a target of 70% self-sufficiency by 2025.  As of 2021, China leads the world with 8 new fabs currently under construction, out of a total of 19 worldwide – that number is expected to increase to 17 by the end of 2023.

Implications - TSMC

As the world’s largest dedicated foundry capable of producing advanced sub-10nm wafers, Taiwan-based TSMC is in an awkward situation – any attempt by the US to interfere with the economic and technology relationships between TSMC and its mainland Chinese semiconductor customers is a major threat to Beijing. The CCP will no doubt reconsider its Taiwan re-unification strategy. 

Taiwan is probably the most important consideration vis-à-vis sanctions, given its oversized role in the value chain, as well as the political conflict resulting from China’s claim that Taiwan is a wayward province.

Taiwan Semiconductor Manufacturing Corp (TSMC) is the world’s largest dedicated semiconductor foundry whose customers include fabless semiconductor companies (AMD, Apple, Broadcom, Marvell, MediaTek, and Nvidia), programmable logic device companies (Xilinx), and even IMD’s (Intel, STMicroelectronics, and TI).

Factoring in all of its production sites, the company has a global capacity of about 14 million 300 mm-equivalent wafers per year (as of 2021). It was the first foundry to produce 7nm and 5nm chips, and the first to use extreme ultraviolet (EUV) lithography technology at scale. Total 2021 revenue was $57.2B, making it one of the largest participants in the semiconductor value chain.

TSMC is uniquely positioned to supply ever smaller, more powerful chips to fabless vendors. Taiwan has benefited from adjacent participants who have established operations on the island: ASE Technology is the world’s largest independent chip assembler, while MediaTek has become the largest smartphone chipset vendor.

in accordance with the Trump administration’s 2020 sanctions against China, TSMC suspended shipments of silicon wafers to Chinese telecommunications equipment manufacturer Huawei and its subsidiary HiSilicon, effective September 2020.

As tensions between Beijing and Taipei have escalated, TSMC has mitigated continuity risk – it has opened, or announced plans to open, new fabs in the US, Japan and Germany.  A $12B plant to be built in Arizona was announced in November 2020 –  as many as six factories may be built in the US with a total $35B investment.

Nevertheless, restrictions on TSMC’s ability to manufacture chips for mainland Chinese companies only exacerbate tensions between the US, China, and Taiwan. By choking off mainland China’s access to TSMC’s advanced manufacturing capabilities, the US may be forcing Beijing’s hand vis-à-vis its political, economic, and technology relationships with Taipei. Simply put – China cannot afford to lose access to TSMC’s expertise and this may precipitate military actions that could have otherwise been avoided.

Implications - ASML

Since China does not have any home-grown advanced lithography technology, one of the key objectives of the sanctions is to block sales of state-of-the-art lithography equipment to Chinese semiconductor manufacturers, thus preventing them from producing sub-10nm IC’s.

EUV and DUV lithography equipment is now included in the sanctions. EUV (or EUVL) refers to advanced extreme ultraviolet lithography, used for sub-10nm wafers, and DUV refers to an older technology called deep ultraviolet lithography, which is used for making less-advanced chips in cars, phones, and consumer computers. Both EUV and DUV technologies were included in the October 2022 sanctions.

As noted above, ASML is a market leader in the DUV sector and has a near monopoly on EUV equipment. Since EUV is relatively new, the bulk of its sales still come from DUV equipment. This is important, because while it has complied with US demands to block EUV sales to China, it has continued supplying DUV equipment, which is used by the bulk of Chinese chip manufacturers.

Because it is a Dutch company, there was initially some confusion as to the potential impact of the latest BIS sanctions, since some of its core components are sourced from US companies.  On its October 25  Q3 earnings call, ASML guided down on China sales and indicated that the restrictions would affect 40% of its sales in that market (assuming it suspended both EUV and DUV deliveries).

UPDATE – In an interview on January 25, 2023,  ASML CEO Peter Wennink said that the US-led strategy against China China’s semiconductor export controls will eventually lead to China’s successful development of its own technology in the field of high-end chip manufacturing equipment. “If they can’t get these machines, they will develop them themselves. It takes time, but in the end, they will achieve their goals.”

UPDATE – as of January, 2023, the Dutch government has not committed to fully supporting the US sanctions banning the sale of EUV equipment to China. This is a significant, as the EUV component is the cornerstone of US sanctions and probably the most difficult for the Chinese to develop on their own.

NOTES

References and Disclaimers

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Works Referenced

“Analyzing China's 2021–2025 Informatization Plan: A Digichina Forum.” DigiChina, 9 Feb. 2022, https://digichina.stanford.edu/work/analyzing-chinas-2021-2025-informatization-plan-a-digichina-forum/.

“Dutch Lithography Giant CEO: U.S. Export Restrictions to China Will Promote China's Successful Development of Its Own Technology.” Teller Report, Teller Report, 26 Jan. 2023, https://www.tellerreport.com/business/2023-01-26-dutch-lithography-giant-ceo--u-s--export-restrictions-to-china-will-promote-china-s-successful-development-of-its-own-technology.SJz1WGKx2s.html.

“The Federal Register.” Federal Register , https://www.federalregister.gov/documents/2022/10/13/2022-21658/implementation-of-additional-export-controls-certain-advanced-computing-and-semiconductor.

“What Is the Bis Entity List and How Does It Apply Globally?” ComplyAdvantage, 4 May 2022, https://complyadvantage.com/insights/us-bis-entity-list/.

Allen, Gregory. “Choking off China's Access to the Future of Ai.” CSIS, https://www.csis.org/analysis/choking-chinas-access-future-ai.

Crawford, Alan, et al. “The World Is Dangerously Dependent on Taiwan for Semiconductors.” Bloomberg.com, Bloomberg, 25 Jan. 2021, https://www.bloomberg.com/news/features/2021-01-25/the-world-is-dangerously-dependent-on-taiwan-for-semiconductors.

Deutsch, Jillian, et al. “Russia Sanctions over Ukraine Worsen Chip Shortage as US, Europe Race China.” Bloomberg.com, Bloomberg, 16 Mar. 2022, https://www.bloomberg.com/news/features/2022-03-16/when-will-the-chip-shortage-end-u-s-eu-spend-billions-in-race-to-beat-china.

Jimenez, Jorge. “New US Sanctions See Semiconductor Suppliers Halt Business with China to 'Protect U.S. National Security'.” Pcgamer, PC Gamer, 18 Oct. 2022, https://www.pcgamer.com/new-us-sanctions-see-semiconductor-suppliers-halt-business-with-china-to-protect-us-national-security/.

Lewis, Morgan. “Sweeping US Export Controls on Semiconductor, Supercomputer Manufacturing in China Raise Compliance Questions.” Publications | Morgan Lewis, https://www.morganlewis.com/pubs/2022/10/sweeping-us-export-controls-on-semiconductor-supercomputer-manufacturing-in-china-raise-compliance-questions.

Lis, Sylwia A., et al. “BIS Issues New Export Controls Targeting China's Advanced Computing and Semiconductor Sectors.” Sanctions & Export Controls Update, 25 Oct. 2022, https://sanctionsnews.bakermckenzie.com/bis-issues-new-export-controls-targeting-chinas-advanced-computing-and-semiconductor-sectors/.

Shen, Qilai. “China Chases Chip-Factory Dominance-and Global Clout.” The Wall Street Journal, Dow Jones & Company, 27 July 2022, https://www.wsj.com/articles/china-bets-big-on-basic-chips-in-self-sufficiency-push-11658660402.

Varas, Antonio, and Raj Varadarajan. “How Restricting Trade with China Could End US Semiconductor Leadership.” BCG Global, BCG Global, 15 Dec. 2021, https://www.bcg.com/publications/2020/restricting-trade-with-china-could-end-united-states-semiconductor-leadership.

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Zweig, David. “America Challenges China’s National Talent Programs.” CSIS, https://www.csis.org/.

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"Things change gradually at first...

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China GDP vs UST Holdings (2010-22) (billions)

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China GDP vs UST Holdings (2010-22) (billions)

Data Source – World Bank

Global FX Exchange Reserves (2001-22) (% of total)

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Global FX Exchange Reserves (2001-22) (% of total)

Data Source – World Bank

Global FX Exchange Reserves (2001-22) (% of total)

(click/tap legend to filter data)
Global FX Exchange Reserves (2001-22) (% of total)

Data Source – World Bank

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