Semiconductor Export Controls Fragment: Nvidia H200 Licences Stall, Nexperia Splits and China Targets Japan

On 28 September 2026 China’s Commerce Ministry confirmed what Washington had announced a few days earlier: the US–China trade truce is extended by two months, to 10 January 2027. With it goes the pause on a US rule that would have extended chip export controls to companies majority-owned by listed Chinese firms.

Two months is the new unit of semiconductor policy. Rules are issued, suspended, licensed, frozen and extended on short timers, and each government runs its own clock. For a chip company, the problem in 2026 is four or five moving regimes that don’t line up.

Washington: from a grand rule to case-by-case deals

In January 2025 the outgoing Biden administration issued the AI Diffusion Rule, a global tiered system for who could buy advanced AI chips. It never took effect. On 12 May 2025, three days before compliance was due, the Commerce Department’s Bureau of Industry and Security rescinded it and promised a replacement without a date. The next day BIS warned that using Huawei’s Ascend chips anywhere risked breaching US controls.

What replaced the grand rule was dealmaking. In August 2025 Nvidia and AMD agreed to pay the US government 15% of revenue from certain chip sales to China in return for licences. In December 2025 President Trump announced Nvidia’s more powerful H200 could be sold to China with a 25% cut for Washington. A January 2026 regulation allowed up to 75,000 units per approved buyer, and about ten Chinese firms were cleared, including Alibaba, Tencent and ByteDance.

Then nothing shipped. After the Trump–Xi summit in May 2026, Beijing still hadn’t approved purchases and reportedly paused orders. China has fallen to about 5% of Nvidia’s revenue, from more than 20%. Washington opened the door and Beijing chose not to walk through it.

The Netherlands: the Nexperia rupture

The Dutch case shows what happens when controls hit ownership. On 29 September 2025 the US Affiliates Rule caught Wingtech, the Chinese owner of Nexperia, a Dutch maker of everyday chips used by carmakers. The next day the Dutch government took control of Nexperia under a 1952 emergency law. China responded on 4 October by banning exports from Nexperia’s Chinese plants, a direct threat to European carmakers that rely on its parts.

Both sides stepped back in November. Washington suspended the Affiliates Rule for a year and The Hague suspended its use of the emergency law. The company stayed broken. A Dutch court ordered a formal investigation in February 2026 and kept Wingtech’s 99% stake with a trustee. Wingtech sued in China for at least 8 billion yuan. In September 2026 a court in Guangdong froze about $318 million of Nexperia assets. Its Dutch and Chinese operations now run, in effect, as two companies.

That’s the fragmentation risk in its plainest form. One government’s export rule became another’s seizure, which became a third’s retaliation. The firm in the middle split in two.

Japan and China: a new front

Japan added 42 mostly Chinese and Russian entities to its own end-user list in February 2025 and tightened controls on chip tools. China has since aimed directly at Tokyo. In January 2026 it banned dual-use exports to Japanese military end users, and in February it put 20 Japanese entities on its export control list.

The rare earth timer

Behind all of it sits China’s leverage on minerals. In October 2025 Beijing announced sweeping new rare earth controls, including rules with reach outside China. After the Trump–Xi deal it suspended them on 7 November 2025, until 10 November 2026. The April 2025 licensing controls on seven heavy rare earths and magnets were never lifted.

Whether the October package stays suspended past November now depends on the wider truce. Washington’s stake-taking in mining companies is the long answer to that dependence. It won’t be ready by November.

Reading the pattern

Export controls used to work best when allies moved together, the US setting rules and the Netherlands and Japan following on chip tools. In 2026 each government is acting more on its own account. Washington trades access for revenue. The Dutch act on corporate control. China retaliates against specific countries and keeps its mineral controls on a timer.

For companies, the practical answer is boring and expensive: map every product against every regime, and assume any of them can change in sixty days.