Samsung Electronics and SK Hynix

Samsung Electronics and SK Hynix are the two South Korean memory-chip manufacturers whose position inside the US-led export-control coalition, while operating major fabrication plants in China, made them the test case of allied burden-sharing in the semiconductor war. Together with Micron they dominate global DRAM and NAND production; unlike Micron, a large share of their capacity sits in the adversary's territory.

Exposure

Samsung's Xi'an complex produces a substantial share of its NAND output, and SK Hynix operates DRAM fabrication in Wuxi and the NAND business in Dalian it acquired from Intel; industry estimates put the Chinese share of each firm's relevant output at roughly two-fifths. The October 2022 US controls on advanced chipmaking equipment therefore aimed at China but struck Seoul: without licences, the Korean fabs could not be upgraded or, ultimately, maintained.

Waiver politics

The accommodation evolved in stages. Both firms first received one-year licence waivers. In October 2023 the Bureau of Industry and Security granted their Chinese subsidiaries Validated End-User authorisations, in effect indefinite permission for specified equipment, a concession negotiated at government level and announced by Seoul as the removal of their largest uncertainty. In a final rule published 2 September 2025, effective 31 December 2025, BIS revoked those authorisations (along with Intel Dalian's legacy authorisation), returning the fabs to case-by-case licensing and signalling that the coalition's tolerance for advanced manufacturing inside China was closing. Both firms are simultaneously recipients of CHIPS Act subsidies for US fabs, subject to the guardrails restricting Chinese expansion.

Significance

The Korean pair illustrate the coalition-management problem inherent in technology-embargo campaigns: controls that bind allies' firms harder than the adversary corrode the coalition, while carve-outs corrode the controls. Their China fabs also complicated the Micron ban of May 2023, when Washington pressed Seoul that its champions should not backfill China's lost Micron purchases. South Korea's dilemma, security alliance with Washington, largest export market in China, runs directly through these two balance sheets.

See also

Semiconductor foundry capacity (TSMC, Samsung, GlobalFoundries) · CHIPS Act and the semiconductor subsidy race (2022-present) · CHIPS and Science Act guardrails (2022) · United States advanced-computing and semiconductor controls on China (2022-present) · South Korea · Entity List (15 CFR Part 744) · Foreign Direct Product Rule · Economic statecraft

Sources

• US Department of Commerce, Bureau of Industry and Security, "Existing Validated End-User Authorizations in the People's Republic of China: Samsung China Semiconductor Co. Ltd. and SK hynix Semiconductor (China) Ltd.", *Federal Register* 88 FR 72558 (20 October 2023).
• US Department of Commerce, Bureau of Industry and Security, "Revocation of Validated End-User Authorizations in the People's Republic of China", 90 FR 42321 (2 September 2025).
• Chris Miller, Chip War: The Fight for the World's Most Critical Technology (Scribner, 2022).