Analysis of New US HBM Export Control Regulations in 2024 and Response Strategies for Chinese Enterprises

With the rapid development of artificial intelligence (AI) technology, High Bandwidth Memory (HBM for short) has become a core component to promote the performance improvement of modern computing systems. However, with the intensification of global technological competition, the United States officially launched new export control regulations for HBM on December 2, 2024. By setting technical parameter thresholds and strict export license requirements, it imposes restrictions on specific countries and regions including China. This article aims to analyze the core content of the new regulations and their impacts, and at the same time provide countermeasures for affected enterprises.

I. What is HBM and its importance

HBM is an advanced storage technology designed specifically for high - performance computing and data - intensive applications. It is widely used in GPUs, TPUs, and other dedicated AI accelerators. Through 3D stacking technology and Through - Silicon Via (TSV) process, HBM achieves high - density integration and high - speed data transmission, which is a key storage solution to meet the needs of AI training and inference.

近年来，HBM技术经历了从HBM1到HBM3E的快速迭代，市场份额主要由三星电子、SK海力士和美光科技三大厂商主导。SK海力士以53%的市场份额占据领先地位，而三星和美光分别占据38%和9%的市场份额。

II. Analysis of the new HBM export control regulations

Core content (What)

The new regulations, through the technology classification of the US Export Administration Regulations (EAR), especially by adding strict technical thresholds under ECCN 3A090.c, include HBM with a memory bandwidth density higher than 2 GB/s/mm² into the scope of strict control. The new regulations emphasize the controlled nature of independent HBM stacks. However, if the HBM has been packaged with a logic chip as a whole, it will be handled according to other provisions. This direct limitation on technical performance ensures the USs precise control over key technologies.

Affected parties (Who)

The new regulations cover all enterprises involved in the export, re - export, or in - country transfer of HBM to China and other countries in Group D:5, including major HBM manufacturers such as Samsung, SK Hynix, and Micron. In addition, all HBM products produced using US technology, equipment, or software, regardless of the place of origin, must comply with this regulation.

Implementation Time (When)

The new regulations came into effect on December 2, 2024, and a compliance buffer period until December 31, 2024, was set. During this period, relevant enterprises need to complete technology classification, license applications, and supply chain adjustments to achieve full compliance.

Scope of Application (Where)

The new regulations apply to the global HBM supply chain. Through the Foreign - Direct - Product Rule (FDPR), the US can exercise extraterritorial jurisdiction over HBM products produced based on its technology. Regardless of where the HBM is produced, as long as US technology or equipment is used, the new regulations must be complied with.

Underlying Intention (Why)

The new regulations aim to prevent specific countries from obtaining advanced HBM technology, thus delaying their technological progress in the fields of AI and high - performance computing (HPC). This is a core means for the US to ensure its technological superiority and national security.

Means of Execution (How)

The US enforces the new regulations through means such as technical parameter control, license applications, and supply chain monitoring. At the same time, it sets license exceptions for some eligible enterprises, allowing them to continue operating under specific conditions.

III. Impact of the New Regulations on the Industrial Chain

Changes in the Global Supply Chain Pattern

The new regulations will significantly affect the stability of the global HBM supply chain. Korean enterprises (SK Hynix, Samsung), as major suppliers, will face additional review pressure for export licenses, while Micron may gain a competitive advantage in the global market with a higher degree of policy compliance.

Impact on Chinese Enterprises

In the short term, Chinese enterprises may face the risks of supply disruptions and cost increases. In AI and HPC projects, the dependence on HBM may lead to restricted technology planning, thus delaying system iterations.

Long - term Impact on the Technological Ecosystem

The new regulations, through precise technical thresholds and a dual - control strategy, block the path for target countries to easily obtain high - performance HBM. At the same time, it prompts enterprises to optimize supply chain management and enhance their own technical capabilities.

IV. Response Strategies of Chinese Enterprises

Short - term Measures: Ensure the Stability of the Supply Chain

• Procurement and Stockpiling: By purchasing HBM2E chips from Korean manufacturers, it provides buffer time for projects.
• Compliance Preparation: Form a professional team, monitor international policy trends, and adjust procurement and inventory management in a timely manner.

Long - term Measures: Autonomization of the Supply Chain

• Technical Research Breakthrough: Concentrate on breaking through core technologies such as TSV and 3D packaging, and promote the research and development of domestic HBM.
• Industry Alliance: Strengthen cooperation between upstream and downstream enterprises and establish a complete local supply chain system.
• Policy Support: Utilize tax incentives and industrial funds to accelerate the commercialization of key technologies.

Risk Management and Diversified Layout

• Diversified Supply Chain: Establish cooperative relationships with multiple suppliers to diversify risks.
• Alternative Plan: Reserve alternative plans for key technology routes to cope with policy changes.

V. Summary and Outlook

The new US HBM export control regulations are not only a technical restriction but also a game in the global technology competition. Facing the challenges of the new regulations, Chinese enterprises need to adopt comprehensive strategies, not only to cope with short - term supply chain pressures but also to achieve technological breakthroughs and industrial chain reconstruction in the long term.

In the future, the technological competition in high - performance memory will intensify further. As a core component of AI and HPC, the development direction and market pattern of HBM will profoundly affect the global technology ecosystem. Only by maintaining a keen market sense and a solid technical foundation can enterprises remain invincible in a complex international environment.