United States of America: Bureau of Industry and Security issued order closing Validated End-User programme for foreign-owned semiconductor fabs in China

On 29 August 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) closed the Validated End-User (VEU) programme, which had, since 2023, allowed certain foreign-owned semiconductor manufacturers to export most United States-origin goods, software, and technology to China without a licence, a status not available to United States-owned fabs. Following the rule, all former VEU participants are required to obtain export licences for such transfers, with a 120-day period from the date of publication in the Federal Register to submit applications. BIS indicated that licences may be granted to enable the continued operation of existing semiconductor fabrication facilities in China, but that licences would not extend to capacity expansion or technological upgrading at those facilities. This decision removes the previous exemption under the VEU programme and places all foreign- and United States-owned semiconductor manufacturers under the same licensing requirements for exports of United States-origin goods, software, and technology to China.