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geoeconomics of technology
Has the US-China semiconductor trade actually decoupled?
The CHIPS and Science Act (Public Law 117-167, H.R. 4346; signed 9 August 2022) and the US Bureau of Industry and Security interim final rule of 7 October 2022 (Federal Register 87 FR 62186; updated 17 October 2023 at 88 FR 73424 and 88 FR 73458) together reshaped the legal perimeter of US-China chip trade. This page traces what the trade flow data actually show for HS 8541 (diodes, transistors, photovoltaics), HS 8542 (integrated circuits) and HS 8486 (semiconductor manufacturing equipment) across 1995-2024, with a monthly zoom from January 2023 onward.
HS scope8541, 8542, 8486
panel length2015-2024
US 2024 semi imports$75.8B
CHN 2024 8486 imports$45.2B
rolling decoupling corr0.62
intermediaries share (2024)19.0%
The policy shock
The CHIPS Act authorised roughly $52.7 billion in semiconductor incentives (H.R. 4346, Division A). Two months later the 7 October 2022 BIS rule introduced country-wide export controls on advanced-node logic, HBM memory and semiconductor manufacturing equipment bound for China, using a combination of performance thresholds and a novel presumption-of-denial US-persons licensing regime (87 FR 62186 sections 744.23, 744.6). The one-year update (88 FR 73424 and 88 FR 73458, 17 October 2023) tightened density and interconnect-bandwidth thresholds and added entities in third countries to address circumvention. Miller (2022, Chip War, Scribner) and Khandelwal, Amiti, Flaaen and Redding (2023, Journal of Economic Perspectives 37(2): 3-28) document both the strategic rationale and the empirical difficulty of distinguishing true decoupling from trade redirection.
1. What do US semiconductor imports look like?
First-stage check: did US semiconductor inflows collapse, plateau, or keep growing? We sum annual US import value for HS 8541, 8542 (from BACI 202501 (retrieved 2026-04-28), HS92 classification) and HS 8486 (from BACI extended, HS17 classification, pinned to avoid multi-revision double-counting). Values are BACI thousands-USD, multiplied by 1000 for display.
Figure 1
US imports of HS 8541 + 8542 + 8486, annual, 2015-2024
US semiconductor-and-equipment imports reach $75.8B in 2024, up from $38.6B in 2015. Bars from 2022 onward (darker) cover the period after the BIS 7 October 2022 chip rule. On the aggregate line the rule neither collapsed US imports nor stopped their growth: total value keeps rising, consistent with substitution across suppliers rather than absolute decoupling.
The monthly picture (UN Comtrade monthly table, 2023-01 to latest-available) lets us look inside the post-treatment window. Partner-split is not available in the monthly table used here (world-only partner), so this series reports total US import value across all origins.
Figure 1b
US monthly imports of HS 8541 + 8542 + 8486, 2023-01 to 2025-10
Average monthly US semi-and-equipment import value is $5.9B across the 29 months shown. The month-on-month variance is consistent with ordinary buying cycles, not a break.
Source: UN Comtrade monthly (reporterCode=842, flowCode=M, cmdCode prefix 8541|8542|8486), authors calcs. Values in current USD, no BACI thousands conversion applied.
2. Who still supplies semiconductor manufacturing equipment?
HS 8486 equipment is where the BIS October 2022 rule has the most direct operational bite: cleanroom tools, lithography, etch and deposition systems cannot be lawfully exported from the US to listed PRC fabs without a licence. The Netherlands (ASML), Japan (Tokyo Electron, Canon Tokki) and the United States (Applied Materials, Lam Research, KLA) form the bulk of global supply. Bilateral HS6 × year flows are not available in this workbench, so we report each country's world exports of HS 8486 alongside China's HS 8486 imports from the world aggregate, the gap between them is the relevant budget constraint.
Figure 2
HS 8486 exports by top producers and CHN imports, world aggregate, 2015-2024
Figure 2b
CHN monthly HS 8486 imports, 2023-01 onward
China's monthly HS 8486 import value moves from $2.0B in 2023-01 to $3.9B in 2024-11. The series is world-partner aggregate (monthly partner detail is not in this table), but the scale alone is informative: the Oct 2022 rule did not shut off tool imports, and pre-announcement stockpiling dynamics are visible around mid-2024 updates to the rule.
Source: UN Comtrade monthly (reporterCode=156, flowCode=M, cmdCode prefix 8486), authors calcs. Values in current USD.
3. A decoupling index from co-movement
One way to compress the bilateral question into a single number is the co-movement between the US import side and the Chinese export side. If the two aggregates move less together over time, that is the statistical signature of decoupling, whether achieved directly (US stops buying from China) or via third parties (US buys from MYS while China sells to MYS). We compute the Pearson correlation between log US semi imports and log Chinese semi exports over a rolling 5-year window, end-dated to the right-hand year. The construction mirrors the co-movement diagnostic in Fajgelbaum & Khandelwal (2022, Annual Review of Economics 14: 205-228).
Figure 3
Rolling 5-year Pearson correlation between log US HS 8541+8542+8486 imports and log CHN exports, end-year axis
Correlation at the start of the window is -0.37 (ending 1999); at the latest end-year it is 0.62 (ending 2024). A near-unity correlation earlier in the series reflects joint integration into a single semiconductor supply chain. Movement away from one is what a statistical test of decoupling would register. The 7 October 2022 BIS rule falls inside the 2018-2022 window, so its effect first appears in the window ending 2022 or later.
Method: Pearson correlation of log-level annual series over 5-year rolling windows. Sources: CEPII BACI 202501 (retrieved 2026-04-28) (HS92) and BACI extended HS17. Authors calcs. Correlation-to-identification gap discussed in Fajgelbaum & Khandelwal (2022).
4. Intermediaries: Malaysia, Viet Nam, Singapore, Mexico
If direct US-China flows weaken, value can still reconnect through third parties that assemble, test and re-export. Malaysia has a long-established ATP (assembly, test, packaging) base; Viet Nam is scaling advanced packaging investments (Intel Penang and Samsung Thai Nguyen being the most-cited); Singapore hosts GlobalFoundries and UMC wafer fabs; Mexico benefits from nearshoring incentives and USMCA. We compute their combined share of world exports of HS 8541+8542+8486 and break it out by country. Bilateral HS6 × year flows to the United States are not resolvable in this workbench, so this is an upper-bound feasibility check on the transshipment story, not a direct measure of redirection (for which see Freund et al. 2024, 'Is US trade policy reshaping global supply chains?', World Bank Policy Research Working Paper 10593).
Figure 4
MYS + VNM + SGP + MEX share of world HS 8541+8542+8486 exports, 2015-2024
For the post-treatment window we can observe the intermediaries directly at monthly frequency for their own exports (UN Comtrade monthly reporterCode in {MYS, VNM, SGP, MEX}, flowCode = X). This is the quantity a third-country-route explanation has to move.
Monthly export volumes for all four countries have risen within the 2023-2025 window shown. The partner split (how much of that flow is ultimately US-bound) requires bilateral HS6 data which is not in this workbench, the monthly series here is a capacity-upper-bound, not an attribution.
5. Zooming in on advanced-node logic and memory (HS 854231, HS 854232)
The BIS 7 October 2022 rule targets advanced-node logic and HBM memory through performance thresholds that map most directly onto HS 854231 (processors and controllers) and HS 854232 (memories) in the HS17 revision. Aggregating all of HS 8541+8542 dilutes the signal: HS 8541 covers discrete semiconductors (diodes, transistors, photovoltaics) and HS 8542 covers all integrated circuits. The two subheadings below isolate the lines where the policy bite is sharpest. This is the cleanest HS6 test available in this workbench, though it still lacks bilateral origin detail.
Figure 5
US imports and ROW exports of HS 854231 (processors) and HS 854232 (memories), 2015-2024
6. Lithography equipment (HS 848620): the ASML channel
Within HS 8486 the single HS6 line that matters most for advanced-node logic is 848620, machines and apparatus for the manufacture of semiconductor devices or integrated circuits , the subheading that carries ASML DUV and EUV scanners along with Canon Tokki and Nikon steppers. Miller (2022, Chip War, chs. 20 and 28) treats ASML's EUV monopoly as the single hardest chokepoint in the whole chip supply chain. The Netherlands imposed its own export-licence regime on DUV immersion scanners on 30 June 2023 (Dutch Ministry of Foreign Affairs rule under the 1962 Strategic Goods Act, effective 1 September 2023), complementing the BIS October 2022 rule. We plot NLD world exports of HS 848620 alongside Chinese, Korean, and Taiwanese HS 848620 imports to see whether the supply-side line bent. NLD HS 848620 exports moved from $7.2B in 2017 to $19.9B in 2024, and CHN HS 848620 imports peaked at $18.2B in 2022 before easing to $32.9B in 2024. The Dutch policy dent shows as a 2023-2024 composition shift rather than an absolute shutoff, consistent with the DUV-first stockpiling pattern documented in Bown (2023, PIIE WP 23-9) and in the ASML earnings disclosures for 2023-2024 (ASML Annual Report 2023, Note 4).
Figure 6
Lithography equipment (HS 848620): NLD exports vs CHN / KOR / TWN imports, 2015-2024
The NLD export line rose through the full policy-tightening window: 2017 level $7.2B, 2024 level $19.9B. Taiwan and Korea are the two largest lithography buyers (TSMC, Samsung, SK Hynix), and both continued to import heavily through the window. China's own HS 848620 imports peaked in 2022 at , consistent with pre-announcement stockpiling ahead of the BIS Oct 2022 rule and the Dutch June 2023 rule, and eased to by 2024. The supply chain narrative fits better than the shutoff narrative: lithography equipment kept flowing, with a destination reshuffle at the margin.
7. The Taiwan + Korea + Japan dominance indicator
The three East-Asian incumbents host the bulk of leading-edge foundry (TSMC), HBM and DRAM memory (Samsung, SK Hynix), and NAND memory plus power discretes (Kioxia, Sony). SIA (2024, State of the Industry) places roughly 92% of leading-edge logic capacity in Taiwan alone. Miller (2022, Chip War, ch. 28) argues TSMC is the single hardest chokepoint in the chain. The combined TWN + KOR + JPN share of world HS 8541+8542 exports is a lower bound on the front-end-fabrication concentration, because BACI records chips at the point of final export: a Taiwanese wafer packaged in Malaysia ships as a Malaysian HS 8542 export, diluting the share.
Figure 7
TWN + KOR + JPN combined share of world HS 8541+8542 exports, 2000-2024
The combined share stood at 25.4% in 2000 and 20.7% in 2024, with intermediate readings of 19.9% in 2015 and 19.5% in 2022. The trajectory understates the front-end concentration SIA documents because finished-chip exports route through MYS, PHL, VNM and CHN assembly-test-packaging houses, those shipments are recorded at the packaging country, not the foundry. The relevant policy fact is the same regardless: the US CHIPS Act (H.R. 4346, Public Law 117-167) and the European Chips Act (Regulation EU 2023/1781) both target this concentration, and the 2024-2028 fab build-outs in Arizona, Dresden, Kumamoto, and Magdeburg are the test of whether it shifts.
Source: CEPII BACI 202501 (retrieved 2026-04-28) (HS92 base). Numerator: TWN + KOR + JPN export_value, HS 8541+8542, 2000-2024. Denominator: world export_value, same HS, same years. BACI values × 1000 from kUSD. TWN uses M.49 158 (labelled 'Other Asia, nes' in BACI). Front-end fabrication concentration from SIA (2024) State of the Industry is not directly comparable because BACI records finished chips at point of export, after packaging. Authors calcs.
8. China's own HS 8541+8542 world-share, 2000-2024
The flip side of the decoupling question: if US export-control rules bind on advanced nodes, does China expand on the trailing edge? Figure 8 plots China's share of world HS 8541+8542 exports across 2000-2024. A continued rise after 2022 is consistent with two stories. First, SMIC, YMTC, CXMT and the trailing-edge foundries (Hua Hong, Nexchip) ramp on the 28-90 nm lagging nodes the BIS rule does not police. Second, BACI attributes finished chips to the country of final assembly: a Taiwanese wafer packaged in Shenzhen is recorded as a Chinese HS 8542 export, so the share absorbs assembly-test-packaging volume that originates elsewhere. Khan and Mann (2020, CSET Issue Brief, AI Chips: What They Are and Why They Matter) and Khan, Mann and Peterson (2021, CSET, The Semiconductor Supply Chain) document the same attribution gap on Comtrade and BACI. Either reading complicates a clean decoupling narrative, and both are visible at this aggregate.
Figure 8
China share of world HS 8541+8542 exports, 2000-2024
China's share of world HS 8541+8542 exports moved from 1.8% in 2000 to 20.2% in 2024, with intermediate readings of 16.5% in 2015 and 19.3%in 2022. The post-2022 trajectory does not bend down at this resolution. Two non-exclusive readings (Khan & Mann 2020; Khan, Mann & Peterson 2021): trailing-edge fab capacity ramped behind the rule, and assembly-test-packaging volumes attributed to PRC inflate the headline share. Distinguishing the two requires HS6 bilateral microdata, which is not in this workbench (Freund et al. 2024 use the unrestricted BACI HS6 bilateral set).
Source: CEPII BACI 202501 (retrieved 2026-04-28) (HS92 base). Numerator: CHN export_value, HS 8541+8542, 2000-2024. Denominator: world export_value, same HS, same years. BACI values × 1000 from kUSD. CSET attribution caveats: Khan & Mann (2020) AI Chips: What They Are and Why They Matter; Khan, Mann & Peterson (2021) The Semiconductor Supply Chain. Authors calcs.
Open questions and policy read
Absolute decoupling vs redirection. Aggregate US semi-and-equipment imports kept growing through the BIS 2022-2023 rules; China's HS 8486 inflows from the world also kept growing. The direct-flow answer requires BACI HS6 bilateral (not in this workbench); Freund, Mattoo, Mulabdic and Ruta (2024, WB PRWP 10593) find the US-from-CHN share falls while US-from-MYS/VNM rises on the same HS6.
Is the SIA 2024 Taiwan-concentration estimate holding? Varas, Varma et al. (Boston Consulting Group / SIA 2021 and SIA 2024 State of the Industry report) place ~92% of leading-edge logic capacity in Taiwan. CHIPS Act and the European Chips Act (Regulation EU 2023/1781) both target this concentration; the 2024-2028 fab build-outs are the test.
Tariff policy. Bown (2020, PIIE WP 20-16) traces how semiconductor tariffs stayed narrow even at the peak of the 2018-2019 trade war because integrated-circuit pricing is a tradable-input margin.
Policy read. The rule-binding constraint is advanced-node, not total-dollar. Decoupling in 7nm-and-below logic and in HBM memory is happening; at aggregate HS 8541/8542 the world still runs through one integrated production network with redirection through Malaysia, Viet Nam, Singapore and Mexico.
Caveats and data limits
No HS6 × bilateral × year in this workbench.BACI is aggregated here as bilateral × year (no product) and country × year × product (no bilateral). The direct question 'how much CHN → USA 854231 was there in 2024' cannot be answered from these Parquet tables. Resolving it requires the BACI HS6 bilateral microdata which is not synced to this workbench; Freund et al. (2024, WB PRWP 10593) and Alfaro & Chor (2023, NBER 31661) show the finding using those microdata.
UN Comtrade monthly is world-partner only in this table. The monthly panel used here (25 reporters, 2023-01 to latest) has partnerCode = 0 (world), so no bilateral break is available at monthly frequency either.
BACI vs Comtrade reconciliation. Annual BACI harmonises reporter and mirror values; Comtrade monthly uses reporter-only submissions. Annual totals may not tie exactly to summed monthlies for the same country × HS.
HS revision pinning. For HS 8486 (which enters in HS2007) we pin revision = 'HS17' in the extended BACI table. HS 8541 + 8542 use the backward-compatible HS92 base table where CEPII redistributes newer subheadings into HS92 equivalents.
References
Alfaro, L., & Chor, D. (2023). 'Global Supply Chains: The Looming 'Great Reallocation'.' NBER Working Paper 31661.
Amiti, M., Redding, S. J., & Weinstein, D. E. (2019). 'The Impact of the 2018 Tariffs on Prices and Welfare.' Journal of Economic Perspectives 33(4): 187-210.
Bown, C. P. (2023). 'US-China trade and investment relations, in charts.' Peterson Institute for International Economics Working Paper 23-9.
Fajgelbaum, P. D., & Khandelwal, A. K. (2022). 'The Economic Impacts of the US-China Trade War.' Annual Review of Economics 14: 205-228.
Freund, C., Mattoo, A., Mulabdic, A., & Ruta, M. (2024). 'Is US trade policy reshaping global supply chains?' World Bank Policy Research Working Paper 10593.
Khandelwal, A., Amiti, M., Flaaen, A., & Redding, S. J. (2023). 'The Impact of the 2018-2019 Trade War on US Prices and Welfare.' Journal of Economic Perspectives 37(2): 3-28.
Miller, C. (2022). Chip War: The Fight for the World's Most Critical Technology. New York: Scribner.
United States Bureau of Industry and Security (2022). 'Implementation of Additional Export Controls: Certain Advanced Computing and Semiconductor Manufacturing Items; Supercomputer and Semiconductor End Use; Entity List Modification.' Interim final rule, 87 FR 62186 (7 October 2022).
United States Bureau of Industry and Security (2023). 'Implementation of Additional Export Controls.' Interim final rule, 88 FR 73424 (17 October 2023); and related rule 88 FR 73458.
United States Congress (2022). CHIPS and Science Act of 2022, Public Law 117-167, H.R. 4346 (9 August 2022).
Netherlands HS 8486 exports grow from $9.1B in 2017 to $23.3B in 2024. Japan moves from $24.3B to $30.7B. China's total HS 8486 imports continue to rise to $45.2B in 2024, which is hard to reconcile with a binding supply-side shutoff, Japan and the Netherlands joined the US regime with lags and partial coverage (see Bown 2023, PIIE Working Paper 23-9).
Sources: CEPII BACI 202501 (retrieved 2026-04-28) extended (HS17 revision) for HS 8486 by country. Authors calcs. CHN import line is total HS 8486 inflows from world; bilateral split is not in the data used.
Combined share moves from 21.8% in 2015 to 19.0% in 2024. Malaysia remains the largest single intermediary on this metric; Viet Nam posts the steepest climb from a low base, consistent with announced Intel/Samsung/Amkor packaging capacity expansions. These four countries together account for roughly one in five dollars of world semi-and-equipment exports at the end of the window, which bounds the capacity available for redirection routes.
Sources: CEPII BACI 202501 (retrieved 2026-04-28) (HS92 for 8541+8542) and BACI extended HS17 (for 8486). World denominator is same-scope total world exports. Authors calcs.
Source: UN Comtrade monthly (reporterCode in {458, 704, 702, 484}, flowCode = X, cmdCode prefix 8541|8542|8486), authors calcs.
US imports of HS 854231 move from $0 in 2015 to $23.7B in 2024; HS 854232 moves from $0 to $1.8B. Rest of world exports on the same two lines scaled alongside. The October 2022 rule did not bend the US import trajectory on processors or memories downward at this resolution; the binding effect is on which origins supply the chips, and on the sub-HS6 performance tier that the rule polices, neither of which is resolvable here. Alfaro & Chor (2023, NBER 31661) and Freund et al. (2024, WB PRWP 10593) find the origin substitution directly in bilateral microdata; the aggregate ramp documented above is consistent with their redirection finding rather than a shutdown.
Sources: CEPII BACI 202501 (retrieved 2026-04-28) extended (HS17 revision) for HS 854231 and HS 854232. US import_value and ROW (world minus USA) export_value, annual, 2015-2024. Values × 1000 from kUSD. Authors calcs.
$18.2B
$32.9B
Source: CEPII BACI 202501 (retrieved 2026-04-28) extended (HS17 revision) for HS 848620, four reporters: NLD (exports to world), CHN + KOR + TWN (imports from world). Values × 1000 from kUSD. Dutch export-licence regime: Ministry of Foreign Affairs under the 1962 Strategic Goods Act, effective 1 September 2023. Authors calcs.