Moolenaar, Whitesides to Secretary Lutnick: Hold Firm on Chinese Memory Chips Ban

Chairman John Moolenaar (R-MI) of the House Select Committee on China and Congressman George Whitesides (D-CA), have sent a letter to Secretary of Commerce Howard Lutnick urging him not to authorize American purchases of memory chips from Chinese companies.

In the letter, the lawmakers write:

"America’s position as the global leader in artificial intelligence is a national achievement and we appreciate recent efforts to safeguard it. However, the scale of this success has contributed to a global shortage of memory chips, including Dynamic Random Access Memory (DRAM) that is essential for the AI industry. The solution to this shortage, however, is not to open the floodgates to a surge of Chinese memory chips, which would aid the Chinese Communist Party’s strategy of distorting markets and destroying profitability as a means to dominate critical industries. We are alarmed that Apple and other U.S. tech companies seek to purchase memory from Chinese semiconductor manufacturers, including those with ties to the Chinese military.

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Dependence on Chinese memory manufacturers creates an unacceptable risk for U.S. national security, economic security, and supply chain security. Leading Chinese memory manufacturers are all closely intertwined with the Chinese military; thus, every memory purchase by a U.S. company will directly subsidize the People’s Liberation Army’s development of this critical dual-use technology. U.S. reliance on Chinese memory producers will expose Western manufacturers to a deluge of state-subsidized Chinese memory, putting our memory manufacturing base and supply chains at risk. Given these risks, we urge you to oppose efforts to facilitate the sale of Chinese memory chips abroad and further expand existing export controls on Chinese memory makers to ensure that they will never catch up to their Western counterparts.

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The United States stands at a defining moment in the global AI race. America’s lead in AI is real, but it is not guaranteed — it must be actively protected from adversarial exploitation. We stand ready to support any legislative action necessary to advance these recommendations and look forward to working closely with your Administration on this critical national security matter."

The letter also makes three policy recommendations:

1. The Bureau of Industry and Security (BIS) should bolster Entity List restrictions on Yangtze Memory Technologies Co., Ltd. (YMTC) and expedite a formal review to add ChangXin Memory Technologies, Inc. (CXMT) to the Entity List, in recognition of its DoD 1260H designation and its role in the PRC’s military-civil fusion strategy.

2. Issue guidance through executive order or agency directive to prohibit U.S. persons and U.S.-incorporated entities from procuring DRAM, High-Bandwidth Memory (HBM), or any other memory components from YMTC, CXMT, or any entity designated on the BIS Entity List or the DoD Section 1260H list, for incorporation into AI systems, data centers, federal information technology, or critical infrastructure deployments. 

3. Work with trusted allies and partner nations such as the Republic of Korea, Japan, and the European Union to implement a coordinated approach to preventing CXMT and YMTC from exploiting the global memory shortage to penetrate allied supply chains.

Read the full letter here.