Letter to the Department of Commerce on DRAM Shortages and Export Licensing for Advanced AI Chips

Chairman John Moolenaar applauds the Department of Commerce for incorporating an “America First” certification requirement into its revised export licensing policy for advanced AI chips, ensuring U.S. customers are prioritized. 

However, the Chairman raises concerns that a global shortage of Dynamic Random Access Memory (DRAM), particularly High-Bandwidth Memory 3 Extended (HBM3E) used in Nvidia’s H200 and Blackwell chips, may undermine the effectiveness of this requirement. With Chinese firms reportedly placing orders far exceeding current supply, the letter warns that exports could divert scarce memory resources away from American companies, threatening U.S. AI leadership. The Chairman requests a briefing on domestic HBM3E availability, its impact on license approvals, and Commerce’s efforts to ensure U.S. customers remain first in line.

Read full letter here.