Evolution of U.S. Chip Controls and the Sullivan Doctrine

Happy holidays from Sinica! This week, I speak with Paul Triolo, Senior Vice President for China and Technology Policy Lead at DGA Albright Stonebridge Group and nonresident honorary senior fellow on technology at the Asia Society Policy Institute's Center for China Analysis.

On December 8th, Donald Trump announced via Truth Social that he would approve Nvidia H200 sales to vetted Chinese customers — a decision that immediately sparked fierce debate. Paul and I unpack why this decision was made, why it's provoked such strong reactions, and what it tells us about the future of technology export controls on China. We discuss the evolution of U.S. chip controls from the Entity List expansions under Trump's first term through the October 2022 rules and the Sullivan Doctrine, the role of David Sacks and Jensen Huang in advocating for this policy shift, whether Chinese firms will actually want to buy H200s given their heterogeneous hardware stacks and Beijing's autarky ambitions, what the Reuters report about China cracking ASML's EUV lithography code tells us about the choke point strategy, and whether selective engagement actually strengthens Taiwan's Silicon Shield or undermines it.

This conversation is essential listening for understanding the strategic, technical, and political dimensions of the semiconductor competition.

6:44 – What the H200 decision actually changes in the real world

9:23 – The evolution of U.S. chip controls: from Entity Lists to the Sullivan Doctrine

18:28 – How Jensen Huang and David Sacks convinced Trump

25:21 – The good-faith case for why export control advocates see H200 approval as a strategic mistake

32:12 – What H200s practically enable: training, inference, or stabilizing existing clusters

38:49 – Will Chinese companies actually buy H200s? The heterogeneous hardware reality

46:06 – The strategic contradiction: exporting 5nm GPUs while freezing tool controls at 16/14nm

51:01 – The Reuters EUV report and what it reveals about choke point technologies

58:43 – How Taiwan fits into this: does selective engagement strengthen the Silicon Shield?

1:07:26 – Looking ahead: broader rethinking of export controls or patchwork exceptions?

1:12:49 – What would have to be true in 2-3 years for critics to have been right about H200?

Paying it forward:

Poe Zhao and his Substack Hello China Tech

Recommendations:

Paul: Zbig: The Life of Zbigniew Brzezinski, Amerca's Great Power Propheti by Ed Luce; Hyperdimensional Substack by Dean Ball

Kaiser: Everything Is Tuberculosis by John Green; The Anthropocene Reviewed by John Green; So Very Small by Thomas Levenson

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