The U.S. government plans to add China-based 3D NAND maker YMTC this week to the Commerce Department’s “entity list,” along with dozens of other tech companies from the People’s Republic of China. Digi TimesCompanies on the Entity List may not source equipment, software and other technology from US companies unless the US company obtains a special export license from the DoC.
As a manufacturer of 3D NAND, YMTC was already facing problems caused by US government policy. Extensive sanctions on China’s semiconductor sectorYMTC has already failed to procure US Wafer Fabrication Equipment (WFE) to manufacture 128+ layers of 3D NAND. As a result, four major US chipmaking tool manufacturers have already stopped cooperating with the YMTC due to the need to obtain appropriate export licenses from the US Department of Commerce.
YMTC becomes even more difficult once you are on the entity list. Because you will lose access to all kinds of wafer fab equipment, including US-manufactured or US-based her IP (including inspection tools), software, and other technology.
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added Yangtze Memory Technologies to its Unverified List (UVL) in early October, along with 30 other entities. Whether he said good intentions were involved in China’s military buildup.
Once a company is registered with UVL, they have 60 days to prove that their products do not violate export control regulations. This usually means that the company must allow his US DoC to conduct inspections and verifications. If the check cannot be completed to the satisfaction of the US DoC, the company will be placed on the Entity List.
The Chinese government appeared to relent last week, allowing US export controls to inspect several organizations (including the YMTC), but these inspections take time. It doesn’t seem to be finished yet, so for the time being I plan to put YMTC and others on the entity list.
Entity lists are essentially blacklists, and being blacklisted is a big deal. Because the YMTC will no longer have access to all regulated American technology. Electronic design automation (EDA) software used for chip design and chips manufactured by TSMC when Huawei and its subsidiaries were added to the Entity List. This severely limited Huawei’s ability to develop system-on-chips and nearly eliminated its ability to mass-produce them.
Now YMTC and 30 other Chinese companies will face the same problem as Huawei, and only time will tell if they can all survive without access to US technology.
