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Taking on the World’s Factory: A Path to Contain China on Legacy Chips

02.06.25 | 21 min read | Text by Andrew Lee

Last year the Federation of American Scientists (FAS), Jordan Schneider (of ChinaTalk), Chris Miller (author of Chip War) and Noah Smith (of Noahpinion) hosted a call for ideas to address the U.S. chip shortage and Chinese competition. A handful of ideas were selected based on the feasibility of the idea and its and bipartisan nature. This memo is one of them.

Challenge and Opportunity

The intelligent and autonomous functioning of physical machinery is one of the key societal developments of the 21st century, changing and assisting in the way we live our lives. In this context, semiconductors, once a niche good, now form the physical backbone of automated and intelligent systems. The supply chain disruptions of 2020 laid bare the vulnerability of the global economy in the face of a chip shortage, which created scarcity and inflation in everything from smartphones to automobiles. In an even more extreme case, a lack of chips could impact critical infrastructure, such as squeezing the supply of medical devices necessary for many modern procedures. 

The deployment of partially- or fully-automated warfighting further means that the deployment of Artificial Intelligence (AI) systems now has direct and inescapable impacts on national security. With great power conflict opening on the horizon, threats toward and emanating from the semiconductor supply chain have become even more evident. 

In this context, the crucial role of the People’s Republic of China (PRC) in chip production represents a clear and present danger to global security. Although the PRC currently trails in the production of cutting-edge sub-16 nm chips used for the development of AI models, the country’s market dominance in the field of so-called “trailing edge chips” of 28 nm or above has a much wider impact due to their ubiquity in all traditional use cases outside of AI. 

The most important harm of this is clear: by leveraging its control of a keystone international industry, the Chinese Communist Party will be able to exert greater coercive pressure on other nations. In a hypothetical invasion of Taiwan, this could mean credibly threatening the U.S. and other democratic countries not to intervene under the threat of a semiconductor embargo. Even more dramatically, given the reliance of modern military manufacture on digital equipment, in the case of a full-scale war between the People’s Republic of China and the United States, China could produce enormous amounts of materiel while severely capping the ability of the rest of the world to meet their challenge. 

A secondary, but significant risk involves the ability of China to build defects or vulnerabilities into its manufactured hardware. Control over the physical components that underlie critical infrastructure, or even military hardware, could allow targeted action to paralyze U.S. society or government in the face of a crisis. While defense and critical infrastructure supply chains represent only a small fraction of all semiconductor-reliant industrial products, mitigation of this harm represents a baseline test of the ability of the United States to screen imports relevant to national security. 

Beyond Subsidies: A Blueprint for Global Manufacturing

Wresting back control of the traditional semiconductor supply chain away from China is widely recognized as a prime policy goal for the United States and allied democratic countries. The U.S. has already begun with the passage of the CHIPS and Science Act in 2022, providing subsidies and tax incentives to encourage the creation of new fabrication plants (fabs) in the United States. But a strategic industry cannot survive on subsidies alone. Preferential tax treatment and government consumption may stand up to some degree of semiconductor manufacture. But it cannot rival the size of China’s if the PRC is able to establish itself as the primary chip supplier in both its domestic market and the rest of the world.

Nascent American foundries and the multinational companies that operate them must be able to survive in a competitive international environment without relying on unpredictable future support. They must do this while fighting against PRC-backed chip manufacturers operating with both a strong domestic market and massively developed economies of scale. Given the sheer size of both the Chinese manufacturing base and its domestic market, the U.S. cannot hope to accomplish this goal alone. Only a united coalition of developed and developing countries can hope to compete. 

The good news is that the United States and its partners in Europe and the Indo-Pacific have all the necessary ingredients to realize this vision. Developing countries in South and Southeast Asia and the Pacific have a vast and expanding industrial base, augmented by Special Economic Zones and technical universities. America and its developed partners bring the capital investment and intellectual property necessary to kickstart semiconductor production abroad. 

The goal of a rest-of-world semiconductor alliance will be twofold: to drive down the cost of chips made in the U.S. and its allies while simultaneously pushing up the cost of purchasing legacy semiconductors produced in China to meet it. Only when these two intersect will the balance of global trade begin to tip back toward the democratic world. The first two slates of policy recommendations will focus on decreasing the cost of non-China production and increasing the cost of Chinese imports, respectively. 

Finally, even in the case in which non-Chinese-influenced semiconductors become competitive with those made in the PRC, it will likely be impossible to fully exclude Chinese hardware from American and allied markets. Therefore, the final raft of policy recommendations will focus on mitigating the threat of Chinese chips in American and allied markets, including possible risks of inbuilt cyber vulnerability. 

The creation of an autonomous and secure supply chain entirely outside of China is possible. The challenge will be to achieve semiconductor independence in time to prevent China from successively weaponizing chip dominance in a future war. With clashes escalating in the South China Sea and threats across the Taiwan Strait growing ever more ominous, the clock is ticking. But America’s Indo-Pacific partners are also increasingly convinced of the urgency of cooperation. The policies presented aim to make maximum use of this critical time to build strategic independence and ensure peace. 

Plan of Action

Recommendation #1: Boosting non-China Manufacturing 

The first and most crucial step toward semiconductor sovereignty is to build and strengthen a semiconductor supply chain outside of China. No matter the ability to protect domestic markets from Chinese competition, U.S. industrial productivity relies on cheap and reliable access to chips. Without this, it is impossible to ramp up industrial production in key industries from defense contracting to consumer electronics. 

According to a report released by the CSIS Wadhwani Center for AI and Advanced Technologies, the global semiconductor value chain broadly involves three components. At the top is design, which involves creating Electronic Design Automation (EDA) software, generating IP, and producing manufacturing equipment. Next is fabrication, which entails printing and manufacturing the wafers that are the key ingredient for finished semiconductors. The final stage is assembly test, and packaging, which entails packaging wafers into fully-functioning units that are fit for sale and verifying they work as expected. 

Of these three, the United States possesses the greatest competitive advantage in the field of design, where American intellectual property and research prowess drive many of the innovations of the modern semiconductor industry. Electronic Design Automation software, the software that allows engineers to design chips, is dominated by three major firms, of which two, Cadence and Synopsys are American companies. The third, Mentor Graphics, is a U.S.-based subsidiary of the German industrial company Siemens. U.S. Semiconductor Manufacturing Equipment (SME) is also an important input in the design stage, with U.S.-based companies currently comprising over 40 percent of the global market share. The United States and Japan alone account for more than two-thirds. 

Meanwhile, the PRC has aggressively ramped up wafer production, aiming to make China an integral part of the global supply chain, often stealing foreign intellectual property along the way to ease its production. Recent reported efforts by the PRC to illicitly acquire U.S. SMEs underscore that China recognizes the strategic importance of both IP and SME as primary inputs to the chip making process. By stealing the products of American research, China further creates an unfair business environment in which law-abiding third countries are unable to keep up with Chinese capacity. 

Semiconductor Lend-Lease: A Plan for the 21st Century 

The only way to the international community is to level this playing field. In order to do so, we propose that the United States encourage and incentivize its companies to license their IP and SME to third countries looking to build wafer capacity. 

Before the United States officially entered into the Second World War, the administration of President Franklin Delano Roosevelt undertook the “Lend-Lease” policy, agreeing to continue to supply allied countries including Great Britain with weapons and materials, without immediate expectation of repayment. Recently, Lend-Lease has been resurrected in the modern context of the defense of Ukraine, with the United States and European powers supplying Ukraine with armaments and munitions Ukrainian industry could not produce itself. 

The crucial point of Lend-Lease is that it takes the form of immediate donations of critical outputs, rather than simple monetary donations, which require time and investment to convert into the desired goods. World War II-era Lend-Lease was not based on a long-term economic or development strategy, but rather on the short-term assessment that without American support, the United Kingdom would fall to Nazi occupation. Given the status of semiconductors as a key strategic good, the parallels with a slow-rolling crisis in the South China Sea and the Taiwan Strait become clear. While in the long term, South, East, and Southeast Asia will likely be able to level up with China in the field of semiconductors, the imminent threats of both Chinese wafer dominance and a potential invasion of Taiwan mean that this development must be accelerated. Rather than industrial and munitions production, as in 1941, the crucial ingredients the United States brought to this process were intellectual property, design tools, and SMEs. These are thus the tools that should be leased to U.S. partners and allies, particularly in the Indo-Pacific. By allowing dedicated foreign partners to take advantage of the gains of American research, we will allow them to level up with China and truly compete in the international market. 

Although the economics of such a plan are complex, we present a sketch here of how one iteration might look. The United States federal government could negotiate with the “Big Three” EDA firms to purchase transferable licenses for their EDA software. The U.S. could then “Lend-Lease” licenses to major semiconductor producers in partner countries such as Singapore, Malaysia, Vietnam, the Philippines, or even in Latin America. The U.S. could license this software on the condition that products produced by such companies will be made available at discounted prices to the American market, and that companies should disavow further investment from or cooperation with Chinese entities. Partner companies in the Indo-Pacific could further agree to share any further research results produced using American IP, making further advancements available to American companies in the global market. 

When growing companies attain a predetermined level of market value they can offer compensation to the United States in the form of fees or stock options, which will be collected by the United States under the terms of the treaty and awarded to the EDA firms. Similar approaches can be taken toward licensing American IP, or even physically lending SME to countries in need. 

Licensing American research to designated partner countries comes with some risks and challenges. For one, it creates a greater attack surface for Chinese companies hoping to steal software and design processes created in the United States. Preventing such theft is already highly difficult, but the U.S. should extend cooperation in standardizing industrial security practices for strategic industries. 

A recent surge in fab construction in countries such as Singapore and India means that the expansion of the global semiconductor industry is already in motion. The United States can leverage its expertise and research prowess to speed up the growth of wafer production in third countries, while simultaneously countering China’s foreign influence on global supply chains. 

A Semiconductor Reserve? 

The comparison of semiconductors to oil is frequently made and has a key strategic justification: for more than a century, oil was a key input to virtually all industrial processes, from transportation to defense production. Semiconductors now play a similar role, serving as a key ingredient in virtually all manufacturing processes. 

A further ambitious policy to mitigate the harm of Chinese chips is to create a centralized reservoir of semiconductors, akin to the Strategic Petroleum Reserve. Such a reserve would be operated by the Commerce Department and maintain centralized holdings of both leading- and trailing-edge chips, obtained from free dealings on the open market. By taking advantage of bulk pricing and guaranteed, recurring contracts, the government could acquire a large number of semiconductors at reasonable prices, sourced exclusively from American and partner nation foundries. 

In the event of a chip shortage, the United States could sell chips back into the market, allowing key industries to continue to function with a trusted source of secure chips. In the absolute worst case of a geopolitical crisis involving China, a strategic stockpile would create a bulwark for the American defense industry to continue producing armaments during a period of disrupted chip supply. This buffer of time would be intended for domestic and allied production to ramp up and continue to supply security functions. 

However, allowing the U.S. to participate in the chip industry has a further impact on economic development. By making the U.S. a first-order purchaser of semiconductors at an industrial scale, the United States could create a reliable source of demand for fledgling businesses. The United States could serve as a transitory consumer buying up excess capacity when demand is weak, ensuring that new foundries are both capable of operation and shielded from attempts from China to smother demand. The direct participation of the U.S. in the global semiconductor market would help to kickstart industry in partner countries while providing a further incentive to build collaboration with the United States. 

Recommendation #2: Fencing in Chinese Semiconductor Exports 

A second step toward semiconductor independence will be in containing Chinese exports, with the goal of reducing China’s access to global markets and starving their industrial machine. 

The most direct approach to reducing demand for Chinese semiconductors is the imposition of tariffs. The U.S. consumer market is a potent economic force. By squeezing Chinese manufacturers seeking to compete in the U.S. market, the United States can avoid feeding additional production capacity that might be weaponized in a future conflict. These tariffs can take a variety of forms and justifications, from increased probes into Chinese labor standards and human rights practices to dumping investigations pursued at the WTO. The deep challenges of effective tariffs is how to enforce these tariffs once they come into play and how to coordinate tariffs with international partners. 

Broad Tariffs, Deep Impact 

No rule works without an enforcement mechanism, and in the worst case, a strong public stance against Chinese semiconductors that is not effectively implemented may actually weaken U.S. credibility and embolden the Chinese government. Therefore, it is imperative to have unambiguous rules on trade restrictions, with a strong enforcement mechanism to match. 

These measures should not just apply to chips that are bought directly from China but rather include those that are assembled and packaged in third countries to circumvent U.S. tariffs. The maximal interpretation of the tariffs mandate would further include a calculated tariff on products that make use of Chinese semiconductors as an intermediate input. 

In the case of semiconductors made in China but assembled, packaged, or tested in other countries, we suggest an expansion of the Biden Administration’s 50% tariff on Chinese semiconductors to include all chips, consumer, or industrial products that include a wafer manufactured in the People’s Republic of China, based on their international market rate. That is, if an Indonesian car manufacturer purchases a wafer manufactured in China with a market value of $3,000, and uses it to manufacture a $35,000 car, importing this vehicle to the United States would be subject to an additional tax of $1,500. 

While fears abound of the inflationary effects of additional tariffs, they are necessary for the creation of an incentive structure that properly contains Chinese manufacturing. In the absence of proportional tariffs on chips and products assembled outside China, Chinese fabs will be able to circumvent U.S. trade restrictions by boosting wafer production that then takes advantage of Assembly, Testing, and Packaging (ATP) in third countries. Further, it is imperative for the United States to not only restrict Chinese chip growth but to encourage the development of domestic and foreign non-China chip manufacturers. Imposing tariffs on Chinese chips as an intermediate ingredient is necessary to create a proper competitive environment. Ultimately, the goal is to ensure a diversification of fab locations beyond China that will create lower prices for consumers overall. 

How would tariffs on final goods containing Chinese chips be enforced? The policy issue of sanctioning and restricting an intermediate product is, unfortunately, not new. It is well known that Chinese precursor chemicals, often imported into Mexico, form much of the raw inputs for deadly fentanyl that is driving the United States opioid epidemic. Taking a cue from this example, we further suggest the creation of an internationally maintained database of products manufactured using Chinese semiconductors. As inspiration, the National Institutes of Health / NCATS maintains the Global Substance Registration System, a database that categorizes chemical substances, along with their commonly used names, regulatory classification, and relationships with other related chemicals. Such a database could be administered by the Commerce Department’s Bureau of Industry and Security, allowing the personnel who enforce the tariffs to also collect all relevant information in one place. 

Companies importing products into the U.S. would be required to register the make and model of all Chinese chips used in each of their products so that the United States and participating countries could impose corresponding sanctions. Products imported to the U.S. would be subject to random checks involving disassembly in Commerce Department workshops, with failure to report a sanctioned semiconductor component making a company subject to additional tariffs and fines. Manual disassembly is painstaking and difficult, but regular, randomized inspections of imported products are the only way to truly verify their content. 

The maintenance of such a database would bring follow-on national security benefits, in that the disclosure of any future vulnerability in a Chinese electronic component would allow quick diagnosis of what systems, including critical infrastructure, might be immediately vulnerable. We believe that creating an enforcement infrastructure that coordinates information between the U.S. and partner countries is a necessary first step to ensuring that tariffs are effective. 

Zone Defense: International Cooperation in the Semiconductor Tariffs 

At first glance, tariff action by the United States on Chinese-produced goods would appear to be a difficult coordination problem. By voluntarily declining an influx of cheaply-priced goods, American consumers exacerbate an existing trade glut in world semiconductor markets, allowing and incentivizing other nations to purchase these chips in greater volume and at a lower price. 

However, rather than dissuading further sanctions in world markets, tariffs may actually spur further coordination in blocking Chinese imports. The Biden Administration’s imposition of tariffs on Chinese electric vehicles coincided with parallel sanctions imposed by the European Union, India, and Brazil. As Chinese overcapacity in EVs is rejected by U.S. markets, other countries face intensified concerns about the potential for below-price “dumping” of products that could harm domestic industry. 

However, this ad-hoc international cooperation is still in a fragile and tentative stage and must be encouraged in order to create an “everywhere but China” semiconductor supply chain. Further, while countries impose tariffs to protect existing automotive and steel industries, global semiconductor manufacturing is currently concentrated in the Indo-Pacific. Thus, coordinating against China calls on countries to not just impose tariffs to protect existing industries, but to impose “nursery” tariffs that will protect nascent semiconductor development, even in places where an existing industry does not yet exist. 

A commonsense first step to building an atmosphere of trust is to take actions protecting partner countries from retaliation in the form of Chinese trade restrictions. In response to EU tariffs on Chinese EVs, Beijing has already threatened retaliatory restrictions on chicken feet, pork, and brandy. For a bloc as large as the European Union, these restrictive sanctions can irritate an important political constituency. For a smaller or less economically powerful country, these measures might be decisive in sending the message that semiconductor tariffs are not worth the risk. 

The United States should negotiate bilateral treaties with partner nations to erect tariffs against Chinese manufacturing, with the agreement that, in the case of Chinese retaliation against predetermined fundamental national industries, the United States government will buy up excess capacity at slightly discounted prices and release it to the American market. This preemptive protection of allied trade will blunt China’s ability to harm U.S. partners and allies. Raising tariffs on imported goods also imposes costs on the Chinese consumer, meaning that in the best case, the decreased effectiveness of these tools will deter the PRC from attempting such measures in the first place. 

Recommendation #3: Mitigating the Threat of Existing Chips 

No matter the success of the previous measures mentioned, it will be impossible to keep Chinese products entirely outside the U.S. market. Therefore, a strategy is required for managing the operational risks posed by Chinese chips that have and will exist inside the U.S. domestic sphere. 

Precisely defining the scope of the threat is very important. A narrow definition of threats might allow threats to pass through, while an overly wide definition may expend time and resources over nothing. A recent British effort to exclude Chinese-made cap badges presents a cautionary tale. By choosing a British supplier over an existing Chinese one after the acquisition process was already underway, the UK incurred an additional delay in its military pipeline, not to mention the additional confusion caused by such an administrative pivot. Implanting GPS-tracking or listening devices within small pieces of metal by one company within the Chinese supply chain seems both impractical and far-fetched– though the PRC surely enjoys the chaos and expense such a panic can cause. 

We consider it analogously unlikely that China is currently aiming to insert intentional defects into its semiconductor manufacturing. First, individual wafers are optimized for their extremely low cost of production, meaning that inserting a carefully designed (and hidden) flaw would introduce additional costs that could compromise the goal of low-cost manufacturing. Any kind of remotely activated “kill switch” would require some kind of wireless receiver–and a receiver of any reasonable strength could not be effectively hidden on a large scale. Second, such a vulnerability would have to be inserted only into wafers that are eventually purchased by the U.S. and its allies. If not, then any attempt to activate a remote exploit could risk compromising uninvolved countries or even the Chinese domestic market, either by accidentally triggering unintended chips or by providing a hardware vulnerability that could be re-used by Western cyber operations. Deliberately planting such vulnerabilities would thus require not just extreme technical precision, but a careful accounting of where vulnerable chips arrive in the supply chain.

Nonetheless, the existence of Chinese chips in the American market can accomplish much without explicitly-designed defects or “kill switches”. Here, a simple lack of transparency may be enough. China currently requires that all software vulnerabilities be reported to the Ministry of Industry and Information Technology, but does not have any corresponding public reporting requirement. This raises the fear that the Chinese government may be ‘stockpiling’ vulnerabilities in Chinese-produced products, which may be used in future cyber operations. Here, China does not need to explicitly build backdoors into its own hardware but may simply decline to publicly disclose vulnerabilities in software in order to attack the rest of the world. 

Shining a Light on Untrusted Hardware 

The likelihood of cooperation between Chinese industry and the CCP exposes a potentially important risk. Chinese software is often deployed atop or alongside Chinese semiconductors and is particularly dangerous in the form of hardware drivers, the “glue code” that ties together software with the low-level hardware components. These drivers by default operate with high privileges and are typically closed-source and thus difficult to examine. We believe that vulnerable drivers may be a key vector of Chinese espionage or cyber threats. In 2019, Microsoft disclosed the existence of a privilege escalation vulnerability found in a Huawei driver. Although Huawei cooperated with Microsoft, it is unclear under the current legal regime whether the discovery of similar vulnerabilities by Huawei would be reported and patched, or if it would be kept as an asset by the Chinese government. The promulgation of Chinese drivers packaged with cheap hardware thus means that the Chinese Communist Party will have access to a broad, and potentially pre-mapped, attack surface with which to exploit U.S. government services. 

The first policy step here is obvious: banning the use of Chinese chips in U.S. federal government acquisitions. This has already been proposed as a Defense Department regulation set to take effect in 2027. If possible, this date should be moved up to 2026 or earlier. In order to enforce this ban, continuous research should be undertaken to map supply chains that produce U.S. government semiconductors. How to accelerate and enforce this ban is an ongoing policy question that is beyond the scope of this paper. 

However, a deeper question is how to protect the myriad components of critical infrastructure, both formal and informal. The Cybersecurity and Infrastructure Security Agency (CISA) has defined 16 sectors of critical infrastructure whose failure could materially disrupt or endanger the lives of American citizens. The recent discovery of the Volt Typhoon threat group revealed the willingness of the Chinese government to penetrate U.S. critical infrastructure using vulnerable components. 

While some of the 16 CISA sectors, such as Government Services and the Defense Industrial Base are within the purview of the federal government, many others, such as Healthcare, Food and Agriculture, and Information Technology, are run via complex partnerships between State, Local, Tribal, and Territorial (SLTT) governments and private industry. Although the best effort should be made to insulate these sectors from over-reliance on China, fully quarantining them from Chinese chips is simply unrealistic. Therefore we should explore proactive efforts at mitigation in the case of disruption. 

A first step would be to establish a team at CISA to decompile or reverse-engineer the drivers for Chinese hardware that is known to operate within U.S. critical infrastructure. Like manual disassembly, this is an expensive and arduous process, but it has the advantage of reducing an unknown or otherwise intractable problem to an issue of engineering. In this case, special care should be taken to catalog and prioritize pieces of Chinese hardware that impact the most critical infrastructure systems, such as Programmable Logic Controllers (PLCs) in energy infrastructure and processors in hospital databases. This approach can be coordinated with the threat database described in the previous section to disassemble and profile the drivers of the highest-impact semiconductor products first. If any vulnerabilities are found, warnings can be issued to critical infrastructure providers, and patches issued to the relevant parties. 

Brace for Impact: Building Infrastructure Resiliency 

Even in the case that neither the reduction of Chinese hardware nor the proactive search for driver vulnerabilities is able to prevent a Chinese attack, the United States should be prepared to mitigate the harms of a cyber crisis. 

A further step toward this goal would be the institution of resiliency protocols and drills for designated critical infrastructure providers. The 2017 WannaCry ransomware attack substantially incapacitated the UK National Health Service by locking providers out of Electronic Medical Record (EMR) systems. Mandating routine paper backups of digital medical records is one example of a resiliency strategy that could be deployed to ensure emergency functioning even in the case of a major service disruption. 

A further step to protect pieces of critical infrastructure is to mandate regular cyber training for critical infrastructure providers. CISA could work in cooperation with State, Local, Tribal, and Territorial regulatory bodies to identify critical pieces of infrastructure. CISA could develop hypothetical scenarios involving outages of critical Information Technology services, and work with local infrastructure providers, such as hospitals, municipal water services, transit providers, and the like, to create plans for how to continue to operate in the event of a crisis. CISA could also prepare baseline strategies, such as having non-internet connected control systems or offline backups of critical information. Such strategies could be adapted by individual infrastructure providers to best protect their services in the event of an attack. These plans could then be carried out in mock ‘cyber drills’ to exercise preparedness in the event of an incident. 

Ultimately, plans of this kind only prepare for service disruptions and do not address the longer-reaching impacts of breaches of confidentiality or the targeted manipulation of sensitive data. However, as we believe that the likelihood of targeted or sophisticated vulnerabilities in Chinese chips is relatively low, these kinds of brute force attacks are the most likely threat models. Preparing for the most basic and unsophisticated service disruptions is a good first step toward mitigating the harm of any potential cyber attack, including those not directly facilitated by Chinese hardware. This cyber-resiliency planning is therefore a strong general recommendation for protecting Americans from future threats. 

Conclusion

We have presented the issue of international semiconductor competition along three major axes: increasing production outside of China, containing an oversupply of Chinese semiconductors, and mitigating the risks of remaining Chinese chips in the U.S. market. We have proposed three slates of policies corresponding to each challenge with some guidance on how to proceed, divided into three complementary categories: 

Boosting non-China semiconductor production 

Containing Chinese exports 

Mitigating the threat of chips in the U.S. market 

We hope that this contribution will advance future discussions on the semiconductor trade and make a measurable impact on bolstering U.S. national security.