Chip Export Controls Don’t Work - Center for European Policy Analysis (CEPA)

Chips & Policy

CEPA Report Argues Chip Export Controls Fail at Core Goal

CEPA argues US-led chip export controls have failed to stop China's semiconductor advance, challenging the bipartisan consensus behind the 2022 restriction regime.

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Grace Kim
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The Center for European Policy Analysis has published a report whose central verdict is blunt: chip export controls do not work. The Washington- and Warsaw-based think tank argues that the US-led restriction regime has failed to halt China's progress in advanced semiconductors, and that policymakers need a different approach.

The report, titled "Chip Export Controls Don't Work," examines the controls the United States has imposed since 2022 on exports of advanced chips and semiconductor manufacturing equipment to China. Those measures restrict sales of leading-edge logic devices, the tools needed to make them, and the involvement of US persons in Chinese advanced fab projects. Allied measures followed from the Netherlands and Japan, the two other homes of critical lithography and deposition equipment.

What does CEPA say has gone wrong?

CEPA's core argument is that the controls have not achieved their stated objective. China continues to build capability in advanced-node production, the report contends, and restrictive measures alone cannot freeze a technological frontier that moves faster than the rules that govern it. The think tank frames the outcome as a gap between the design of the controls and their real-world effect on Chinese industry.

The report's assessment carries weight because of its source. CEPA is an established transatlantic policy institution with a focus on European security and on strategic competition with Russia and China. Its conclusion cuts against the current of policy in Washington, where export controls on semiconductors enjoy broad bipartisan support as a tool for slowing Chinese military modernization.

How does this fit the wider policy debate?

The report lands in the middle of an active argument over sanctions policy. Critics of the controls have long made three points, and CEPA's analysis aligns with them:

  • Export controls create incentives for Chinese firms to indigenize chipmaking faster, through state-funded programs and local toolmakers.
  • Unilateral or partially coordinated measures leave gaps when supplier countries do not all enforce the same rules.
  • Enforcement resources lag the complexity of the supply chains being policed, from chip smuggling to transshipment through third countries.

Supporters of the controls counter that the measures were never meant to stop China permanently. On that view, the goal was to buy time — to slow the absorption of advanced computing power into Chinese military systems and to preserve a Western lead at the most critical nodes. CEPA's report challenges whether that time has in fact been bought.

What is the commercial picture for the industry?

For semiconductor suppliers, the policy fight is not abstract. US toolmakers and chip designers have lost revenue in one of their largest markets since the 2022 controls took effect, and they watch each regulatory revision for changes in license scope. Chinese customers have responded by accelerating orders to domestic equipment and materials producers, a substitution dynamic that reshapes vendor market shares on both sides of the restrictions.

The report's timing matters for regulators. The US Commerce Department has revised its rules repeatedly since October 2022, tightening definitions of covered chips and adding entities to restriction lists. European and Japanese authorities have moved toward alignment, at varying speeds. A think tank verdict that the entire framework underperforms will feed calls in Washington and Brussels for either stricter enforcement or a strategic rethink.

What comes next?

CEPA's contribution is a judgment, not a dataset, and readers should weigh it accordingly: the report makes a case about policy effectiveness rather than publishing new fab-level or shipment figures. Its significance lies in who is making the argument, and in how directly it questions the consensus behind the current export control architecture. Expect the paper to surface in the next round of transatlantic debate over how, and whether, to control advanced chip technology — with the competitive dynamics between US, allied, and Chinese suppliers hanging on the answer.

Source: Google News: chip export controls

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Grace Kim

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Market editor covering people, launches and day-to-day practice in Semiconductors, chip manufacturing, hardware, AI compute at Chip Dispatch.

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