In response to the latest chip export control requirements in the United States, industry associations and companies in the United States are expressing concerns about the policy to the US government through formal feedback procedures.
John Neuffer, President and CEO of the Semiconductor Industry Association (SIA), recently wrote to Alan Estevez, Deputy Secretary for Industry and Security at the US Department of Commerce, requesting an extension of the comment period for new regulations, from the original 60 days to 90 days.
Just this week, the latest document submitted by chip giant Nvidia to the US SEC showed that the US restrictions on the sale of some Nvidia products to markets such as China had come into effect on October 23rd. On October 17th, the US government announced that the new sales restriction rules will take effect 30 days after public consultation, and set the industry comment deadline to 60 days.
During the industry opinion review period, companies can still evaluate and provide opinions on the content of the new regulations and rules, as learned by journalists from First Financial.
Neuffer from SIA stated that the new regulations are nearly 450 pages long and very complex, and SIA is working closely with member companies to understand the impact of the new regulations on the semiconductor industry. A more relaxed consultation and comment period helps SIA provide more comprehensive opinions.
SIA's request has also received support from chip manufacturers. In a statement sent to First Financial reporters, Robert Hoffman, the head of government affairs at Broadcom, stated: "Broadcom supports the Semiconductor Industry Association of America's request to extend the deadline for seeking opinions on new export control regulations in the United States. Trade policy formulation must be cautious to avoid unnecessarily placing American companies at a disadvantage in competition and innovation in China and other important global markets
Bo Tong also responded to reporters from First Financial that the company is still evaluating the impact of the new regulations on specific products, but has not disclosed which product types will be immediately affected.
Botong's product portfolio targets markets including data centers, networks, software, broadband, wireless, storage, and industrial products. As of August 31, the third quarter results showed that Broadcom's revenue increased by 5% year-on-year to $8.9 billion, and it is expected that the fourth quarter revenue will increase by 4% year-on-year to $9.27 billion.
The Chinese market is also one of the most important markets for Broadcom globally. Botong has over 600 employees in China and continuously invests in research and development. In the fiscal year 2022, Broadcom's global R&D investment is approximately $5 billion, accounting for approximately 15% of total revenue.
Nvidia has previously disclosed details of restricted chip products, but pointed out that there are still some unclear aspects of the new regulations. NVIDIA stated in a Form 8-K document on October 18th that "the temporary rules impose additional licensing requirements on exports, provided that the company's integrated circuits exceed certain performance thresholds (including but not limited to A100, A800, H100, H800, L40, L40S, and RTX 4090)." However, the document did not specify what these performance thresholds are.