A report by the American nonprofit C4ADS outlines the various ways advanced American AI accelerators, specifically Nvidia chips, are being acquired by entities in China. Despite U.S. export restrictions on high-end chips like H100, A100, and Blackwell-family GPUs, and China's stated policy to discourage American AI chip purchases, these products are still entering the Chinese market. The report suggests the actual volume of smuggled hardware could be higher than identified.
C4ADS identified three main channels for chip smuggling. The first involves direct acquisitions by Chinese universities and research institutions, which embed Nvidia GPUs within multi-vendor contracts routed through regional integrators. Some of these institutions reportedly have ties to China's defense and intelligence sectors. The report tracked 56 chips valued at $1.7 million sold this way between July 2025 and January 2026. An earlier investigation by C4ADS covering multiple years found $6.48 million worth of such sales.
The second method involves drop-shipping through other Southeast Asian countries, where chips are rerouted to China. The third method utilizes complex structures of shell companies to obscure the final destination of the chips.
The U.S. prohibits the sale of H100, A100, and Blackwell-family chips to China. Lower-end chips like the H20 and H200 (and AMD MI325X) can be traded on a case-by-case basis, with the H200 incurring a 25% tariff. China officially discourages the purchase of American AI chips to foster its domestic industry, led by Huawei. However, reports indicate that Chinese authorities often overlook gray and black-market imports, and exceptions were granted to companies like ByteDance, Alibaba, and Tencent in 2026.
An earlier report by Epoch AI estimates that approximately one-third, and potentially most, of China's AI compute power relies on smuggled GPUs. This indicates a significant bypass of international trade restrictions, impacting both U.S. export control effectiveness and China's domestic AI development goals.
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