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How Will New Export Controls Impact the Global Semiconductor Shortage?

The U.S. mirrors tactics used against China on Russia as war in Ukraine escalates.

A worker in a dust-proof suit controls an LED epitaxy chip production line at a semiconductor workshop in Nanchang, in China's Jiangxi Province on Jan. 26.

A worker in a dust-proof suit controls an LED epitaxy chip production line at a semiconductor workshop in Nanchang, in China's Jiangxi Province on Jan. 26. Costfoto/Future Publishing via Getty Images.

The scale and combination of coercive economic measures imposed on Russia by a growing coalition of states in response to Putin’s invasion of Ukraine are unprecedented. On February 24, 2022, forty-nine Russian and two Belarusian entities were added to the U.S. Bureau of Industry and Security (BIS) Entity List, effectively cutting them off from accessing key U.S. technology, including semiconductors. 

Semiconductors (or chips) are the lifeblood of modern technology, enabling devices from smartphones, to automobiles, to hypersonic weapons. In addition to the direct measures against Russia and Belarus, the United States, its allies, and major producers in the semiconductor supply chain have imposed similar export controls on other countries and companies that are supporting Russia’s military campaign in Ukraine. The new restrictions could choke off the Russian economy’s access to Western technology and devastate sectors critical to its economy, including energy, defense, aerospace, maritime, and telecommunications—all of which depend on the essential chips.

These latest developments are set against the backdrop of record inflation and global supply chain bottlenecks, with firms around the world grappling to recover from the pandemic. In the automotive industry alone, chip shortages cost companies $210 billion in revenue in 2021, and losses are set to get worse. The U.S. Department of Commerce reports that due to limited chip supply, companies are holding less than five days’ worth of inventory compared to forty days in 2019. Any additional shocks to the supply chain could further undercut companies’ output and revenue.

In his first State of the Union address, President Biden urged Congress to pass legislation to support $52 billion worth of federal investments and tax credits for domestic semiconductor research, development, and manufacturing to meet surging demand. The call is part of the administration’s effort to maintain U.S. leadership in the semiconductor manufacturing, boost domestic manufacturing, and strengthen competitiveness. Notable are Intel’s plans to build a $20 billion chip factory in Ohio which could increase to $100 billion over the next ten years with federal support. However, even with government incentives, given that it takes on average of three to five years to build one manufacturing facility, it will likely be years before U.S. firms can ramp-up domestic manufacturing.

How we got here, the implications of export controls on Russia, and the potential impacts on the semiconductor supply chain and the global economy are discussed below.

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The scale and combination of coercive economic measures imposed on Russia by a growing coalition of states in response to Putin’s invasion of Ukraine are unprecedented. On February 24, 2022, forty-nine Russian and two Belarusian entities were added to the U.S. Bureau of Industry and Security (BIS) Entity List, effectively cutting them off from accessing key U.S. technology, including semiconductors. 

Semiconductors (or chips) are the lifeblood of modern technology, enabling devices from smartphones, to automobiles, to hypersonic weapons. In addition to the direct measures against Russia and Belarus, the United States, its allies, and major producers in the semiconductor supply chain have imposed similar export controls on other countries and companies that are supporting Russia’s military campaign in Ukraine. The new restrictions could choke off the Russian economy’s access to Western technology and devastate sectors critical to its economy, including energy, defense, aerospace, maritime, and telecommunications—all of which depend on the essential chips.

These latest developments are set against the backdrop of record inflation and global supply chain bottlenecks, with firms around the world grappling to recover from the pandemic. In the automotive industry alone, chip shortages cost companies $210 billion in revenue in 2021, and losses are set to get worse. The U.S. Department of Commerce reports that due to limited chip supply, companies are holding less than five days’ worth of inventory compared to forty days in 2019. Any additional shocks to the supply chain could further undercut companies’ output and revenue.

In his first State of the Union address, President Biden urged Congress to pass legislation to support $52 billion worth of federal investments and tax credits for domestic semiconductor research, development, and manufacturing to meet surging demand. The call is part of the administration’s effort to maintain U.S. leadership in the semiconductor manufacturing, boost domestic manufacturing, and strengthen competitiveness. Notable are Intel’s plans to build a $20 billion chip factory in Ohio which could increase to $100 billion over the next ten years with federal support. However, even with government incentives, given that it takes on average of three to five years to build one manufacturing facility, it will likely be years before U.S. firms can ramp-up domestic manufacturing.

How we got here, the implications of export controls on Russia, and the potential impacts on the semiconductor supply chain and the global economy are discussed below.

Huawei rotating chairman Guo Ping speaks during the Huawei Global Analyst Summit 2020 at the Huawei headquarters in Shenzhen, China on May 18, 2020.
Huawei rotating chairman Guo Ping speaks during the Huawei Global Analyst Summit 2020 at the Huawei headquarters in Shenzhen, China on May 18, 2020. Noel Celis/AFP via Getty Images.

The U.S. applies its China export control strategy to Russia

U.S. export controls typically regulate the flow of technology to foreign adversaries that are deemed by the president and Congress to pose national security risks. To deter Putin and undermine Russia’s military campaign, the Biden administration is strategically leveraging a relatively new tool in the United States’ economic toolkit—the foreign direct product (FDP) rule.

The FDP rule requires that foreign firms obtain a license for any dual-use products (or commercial technology that can have a military application) that rely on U.S. technology or software. The rule was notably utilized under the former Trump administration to target Chinese tech firms, specifically Huawei, by banning any chip sales to the tech giant if U.S. semiconductor manufacturing equipment or software was used during the production process. Given the United States’ dominance in the chip supply chain, this action virtually cut off Huawei’s access to semiconductors.

As compared with the rules imposed on Huawei, the export controls and FDP rule imposed on Russia and Belarus are far more extensive as they cover a wider range of products and restrict the flow of any foreign items made with U.S. technology or software, except for food and medicine. In effect, the rules prohibit a suite of items that potentially have a military end use and rely on U.S. technology, software, or equipment, such as semiconductors, from being sent to Russia or Belarus.

When the FDP rule was applied to China in 2020, industry groups criticized unilateral action by the United States as the move applied extraterritorial reach of U.S. law on foreign firms. Skeptics raised concerns that it would deter firms from doing business with U.S. companies as foreign firms were required to abide by U.S. restrictions if they also relied on any U.S. technology or software. However, unlike with China, the rules imposed on Russia and Belarus are based on a multilateral approach. More than thirty countries, including major chip producers, such as the European Union (EU), Japan, Singapore, South Korea, and Taiwan, are actively imposing export controls in response to the conflict in Ukraine. The grave threat that Russia’s actions in Ukraine pose to global security and economic stability has prompted countries to coordinate with the United States, which is a departure from the approach in the Huawei case, when the United States imposed export controls unilaterally. As a result of this unprecedented, allied cooperation, the U.S. Department of Commerce is exempting countries that adopt similar controls from U.S. FDP rules.

The full effects of the new export controls on Russia, which are part of a broader set of punitive economic measures, are yet to be seen. However, they are already generating blowback. Putin has threatened to issue sanctions on critical minerals, including those needed to produce semiconductors—a move that would significantly impact U.S. military equipment manufacturing, in particular. Chipmakers around the world have tried to diversify their supply chains, but Russia and Ukraine remain key players in the global supply chain. Russia controls approximately 43 percent of global palladium production, and Ukraine supplies approximately 70 percent of the world’s neon gas, including 80 to 90 percent of all U.S. imports, both of which are an essential components in chip manufacturing. In 2014, Russia’s annexation of Crimea caused neon prices to skyrocket by 600 percent. Although chip companies predict that the industry will face little immediate disruption from Russia’s invasion of Ukraine, the cascading impacts of deteriorating U.S.-Russia trade relations and a potential trade war would have far-reaching implications beyond semiconductors.

EU Commissioner for Internal Market Thierry Breton gives a speech during a ceremony about the European Chips Act in Brussels, Belgium on Feb. 8.
EU Commissioner for Internal Market Thierry Breton gives a speech during a ceremony about the European Chips Act in Brussels, Belgium on Feb. 8. Thierry Monasse/Getty Images.

Countries accelerate indigenization efforts as supply chain disruptions worsen

Heightened concerns of limited access to essential chips, slowed economic growth, and the potential for further damage to already-strained global supply chains make it likely that countries globally will accelerate their chip indigenization strategies and make long-term investments in alternative supply chains. Indeed, the recent export control measures targeting Russia, and concomitant trade disruptions carry cascading impacts for industrial sectors—notably in Europe. The EU is Russia’s largest trading partner, and Russia is the EU’s fifth largest trading partner, with their total trade amounting to 174.3 billion euros (USD 197.1 billion).

In early February 2022, the European Commission proposed a suite of regulatory changes through the European Chips Act. The Act proposes 43 billion euros ($49 billion) worth of investment to increase chip production across Europe (a figure that attempts to rival the $52 billion funding levels proposed in the United States) and is part of a broader, more ambitious effort by the EU to quadruple its current global semiconductor output from 5 percent to 20 percent by 2030. While the Act still requires approval from the European Parliament and member states, it demonstrates countries’ mounting concerns regarding their dependence on others for access to essential products and services. Beyond Europe, Japan, South Korea, and Taiwan have announced similar plans to boost domestic chip and semiconductor manufacturing equipment production and deepen their economic ties with allies and partners to strengthen supply chain resiliency.

The flux in the chip global supply chain and heightened concerns of China’s potential response in the Taiwan Strait following Russia’s military incursion in Ukraine may incentivize Taiwan to seek stronger economic and diplomatic ties with key Western countries. In 2021, the world’s largest chip manufacturer, Taiwan Semiconductor Manufacturing Company (TSMC), announced plans to invest $100 billion over the next three years to expand its production capacity, which could include fabrication facilities (“fabs”) outside of the Asia region. TSMC has expressed interest in establishing its first European fab in Germany, which is a key player in supplying top-of-the-line lasers for chip manufacturing. Although the EU has no official diplomatic ties with Taiwan, Taiwan is the EU’s fifteenth largest trading partner and the EU is Taiwan’s fourth largest trading partner, with their bilateral trade totaling over $35 billion in 2020. Taiwan may continue to leverage its current position in the global supply chain with respect to semiconductors, and more broadly, to strengthen its ties with Europe to counter Chinese pressure.

Even if the crisis in Ukraine accelerates indigenization efforts, it will take years for countries to expand manufacturing capacity, shore up the necessary talent, and solidify the competitiveness of firms in the chip industry. It is highly unlikely that countries will be able to replicate the complex global ecosystem domestically given that American, Chinese, European, South Korean, Japanese, and Taiwanese firms will remain the primary suppliers of distinct technology and materials that others in the semiconductor supply chain rely upon. Thus, an allied strategy is needed.

The unintended consequences of export controls and economic statecraft

Due to the highly interconnected nature of the global supply chain, U.S. export controls on semiconductors could also have a range of unintended consequences. First, manufacturers are increasingly finding themselves caught in the crosshairs of intensifying geopolitical competition, being forced to choose sides to avoid retaliation. For example, China’s anti-foreign sanctions law passed in June 2021, subjects companies doing business in China to penalties should they abide by U.S., EU, and other foreign governments’ sanctions. This leaves firms at higher risk of being targeted by Chinese authorities. Similarly, the Biden administration has stated that if companies are found to be violating current export controls on Russia, they will be put on the U.S. Department of Commerce’s Entity List.

Second, while export controls on semiconductors are a powerful tool, they could also drive closer Sino-Russo strategic cooperation. Both strategic competitors with the U.S., in February 2022, China and Russia issued a joint statement that outlined their plans for broader economic and technological “friendship.” Indeed, China is Russia’s largest trading partner, with their trade growing from $10.7 billion in 2001 to $140 billion in 2021. One of the main drivers of Sino-Russo cooperation is Russia’s need for technology and capital that China can provide in exchange for natural resources from Russia’s enormous reserves. Meanwhile, Putin may look to leverage Russia’s influence over the abundance of Arctic natural gas and energy reserves to deepen its connections with China. Experts also warn that in response to the sanctions, Russia may deepen its non-dollar-denominated trade ties and seek support from China in order to evade U.S. sanctions—a move that could in the long run undermine U.S. dominance in the international financial system.

Intensifying Western sanctions on Russia stands to strengthen Russia-China economic and tech partnerships, particularly given that Russia already purchases 70 percent of its chips from China. While China is weighing the degree to which it will support Russia in Ukraine, given the threat of potential secondary sanctions, the Biden administration’s actions on export controls and semiconductors may ultimately be constrained by potential opposition from domestic tech companies. The U.S. tech industry is highly dependent on revenue and global supply chains that flow through China. About 80 percent of U.S. firms’ export revenue comes from abroad, 36 percent of which is from China. Export revenue is essential for companies’ ability to reinvest in vital research and development initiatives that allow U.S. firms to remain at the cutting edge of their sectors.

Looking Ahead

As tensions in Ukraine escalate, the EU-U.S. Trade and Technology Council (TTC), established in June 2021, has a greater role to play in harmonizing allies’ approach to mitigating and managing consequences from their sanctions package. While the TCC is currently focused on short-term supply chain issues, the Council’s meeting in 2022 will be one to watch to see if the United States and its allies can coordinate a mid- to long-term strategy with respect to semiconductors. Experts warn that current export controls on semiconductors could widen to advanced, commercial chips that do not have specific military applications, but offer high-tech capabilities in critical emerging technology sectors. Such a move would escalate the already broad category of items covered in the current export controls to include, for example, graphic-processing chips used in artificial intelligence (AI), amounting to a near blockade of any key technologies that Russia would rely on.

To learn more about semiconductors and intensifying geostrategic competition, see FP Analytics’ Semiconductor and the U.S.-China Innovation Race special report, which examines the interconnectivity and fragility of global supply chains and the central role of Taiwan in global tech competition.

For a comprehensive breakdown of the key factors determining the future of 5G technology and infrastructure, see FP Analytics’ 5G Explained Power Map.


Gahyun Helen You is a policy analyst at FP Analytics, the research and advisory arm of Foreign Policy. Her research focuses on international security, economics, cyber and technology policy, and governance. She is a graduate of New York University.

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Semiconductors and the U.S.-China Innovation Race

The lifeblood of high-tech industries, semiconductors are at the heart of intensifying U.S.-China strategic and economic competition. Escalating trade tensions between these two superpowers and a range of protective measures have had cascading impacts that are threatening global supply chains, firms’ competitiveness, and end-users’ access to these vital materials. FP Analytics’ Special Report examines the interconnectivity and fragility of global supply chains and the central role of Taiwan in global tech competition.

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