The US-China know-how conflict and its results on Europe

The US-China know-how conflict and its results on Europe


The know-how conflict between the US and China has taken a brand new flip as the 2 international locations’ race to subsidise their industries gathers tempo. The dearth of an formidable response and versatile enterprise assist measures from the EU may have critical penalties for European competitiveness and industrial improvement.


This paper analyses the financial and political causes and developments within the know-how conflict between the US and China, which started in 2015 and continues to escalate. The Biden Administration has complemented export management measures with a drive to maximise the technological distance between the 2 opponents by large-scale incentives within the type of subsidies and tax breaks. Nevertheless, these introduce harmful imbalances into the worldwide enjoying subject, with the potential to have an effect on different actors such because the EU.


Crucial commerce conflict in the previous few years has not been the tariff conflict initiated by Trump. In distinction to what some would possibly assume, it has been the know-how conflict between the US and China, which started on the finish of the Obama period, gathered tempo throughout the Trump presidency and has additional escalated beneath the Biden Administration. The conflict has two features: first, to cease China catching up with US technological supremacy (with all of the related financial and army implications) by blocking know-how switch; and, secondly, to maximise the technological distance between the US and China, subsidising nationwide manufacturing. This latter facet has main penalties for the EU, with the potential to create a harmful lag in know-how.

Semiconductors and their worth chain

The present state of affairs might be largely defined by the technological significance of semiconductors and their worth chain.

Semiconductors are supplies that may act as conductors (permitting present to cross by) or insulators (stopping its passage), relying on quite a few circumstances (eg, temperature, stress, radiation or magnetic fields). This binary perform makes them extraordinarily helpful for the electronics and IT industries.

They are often categorised into two sorts, relying on their purity: intrinsic or pure; and extrinsic or ‘doped’. The previous embody silicon (essentially the most extensively used semiconductor, since it’s the mostly present in nature and behaves finest at excessive temperatures), germanium, tin, selenium and tellurium. The second are pure semiconductors to which impurities are added to extend conductivity.

Semiconductors are used within the manufacture of a spread of merchandise, primarily transistors (amplifiers, switches, oscillators and rectifiers for electrical alerts, utilized in radios, watches and lights), diodes (crystals that solely permit electrical present to stream in a single route, used to transform AC to DC in photo voltaic panels or for LED lights) and chips (processors and reminiscence for computer systems, tablets and cell units). This final class is a very powerful.

A chip (additionally referred to as a microchip or built-in circuit) is a set of digital circuits superimposed on a small flat piece of silicon (essentially the most generally used materials and the second most ample materials in Earth’s crust) referred to as a wafer. There are two kinds of chips: logic chips, which course of common data (central processing items or CPUs, the ‘brains’ of computer systems), graphical data (GPUs, also referred to as video playing cards), audio (APUs, audio playing cards) and neural data (NPUs, for deep studying and machine studying functions); and reminiscence chips, which retailer dynamic random entry data (DRAM, which is extraordinarily quick however risky) or everlasting data (NAND Flash, slower however much less risky, equivalent to USB sticks and SD playing cards). All these chips are utilized in a spread of digital units, together with telephones, video games consoles, vehicles and medical gear. Chips classed as mature –greater than 40 nanometres (nm)– are continuously utilized in industries such because the automotive business. Probably the most superior chips are lower than 16nm, with a mean measurement of 10nm (though as much as 3nm has been achieved).

The chip worth chain is functionally and geographically complicated. World manufacturing is structured round 5 kinds of producers:

  • Fundamental builders, which deal with the preliminary design section and embody Cadence, Synopsis, CEVA and Lattice within the US, the German agency Mentor Graphics, and Arm within the UK (lately topic to a failed take-over by Nvidia).
  • Superior builders with out factories (fabless manufacturing), which produce complicated or specialised designs and outsource their manufacture. Examples embody Qualcomm, Nvidia, AMD, Xillinks and Marvell within the US, MediaTek in Taiwan and HiSilicon in China (owned by Huawei).
  • Pure producers or foundries, which produce chips beneath contract for different firms. Examples embody the Taiwanese companies TSMC (a technological chief) and UMC, World Foundries within the US and SMIC in China. Foundries use superior equipment (slicing, measurement, and many others) from the US companies Utilized Supplies, Lam Analysis and KLA, the Dutch agency ASML and the Japanese firms Tokyo Electron, Nikon and Canon Tokki, along with supplies like silicon wafers and photomasks produced by the Japanese companies Shin-Etsu, Sumco, JSR and Tokyo Onika.
  • Meeting, testing and packaging (ATP) companies, that are answerable for the ultimate section of the product. Examples embody ASE Expertise and Powertech in Taiwan, the Chinese language firms JCET and UTAC, and the US agency Amkor.
  • Built-in Machine Producers (IDMs), which carry out all of the above features throughout the similar company group. Examples embody the US companies Intel, Infineon and Texas Devices, and Samsung and SK Hynix in Korea. Some additionally present foundry providers for different firms.

The geographic distribution of the semiconductor worth chain is proven in Determine 1. The numerous relative weighting of the US in comparison with the EU is evident.

Determine 1. Geographic distribution of the semiconductor worth chain (market share by nation in every section)

The US-China know-how conflict and its results on Europe
Supply: Kearney (2021).

Determine 2 reveals the primary firms by market share as of 2021. Samsung and Intel make up 1 / 4 of the IDMs and fabless market, whereas TSMC makes up over half of the foundry market.

Determine 2. Main semiconductor producers (market share 2021)

Producers (excluding foundries) % Foundries %
Samsung (South Korea) 12.3 TSMC (Taiwan) 56.6
Intel (US) 12.2 Samsung Foundry (South Korea) 8.5
SK Hynix (South Korea) 6.1 UMC (Taiwan) 7.6
Micron Expertise (US) 4.8 GlobalFoundries (US) 6.6
Qualcomm (US) 4.6 SMIC (China) 5.4
Nvidia (US) 3.2 PSMC (China) 2.3
Broadcom Restricted (US) 3.0 HH Grace (China) 1.6
MediaTek (Taiwan) 2.9 Vanguard (Taiwan) 1.6
Texas Devices (US) 2.8 Tower Semiconductor (US) 1.5
AMD (US) 2.7 HLMC (China) 1.3
Others 45.4 Others 7.0
Supply: Gartner.

The origin of the conflict: Made in China 2025

The know-how conflict between the US and China has two interrelated causes, the primary financial, the second political. The financial dimension stems from China’s need to construct its industrial capability and work its means up the value-added ladder, an method clearly set out in its Made in China 2025 industrial technique and coverage. Unveiled in Could 2015 as a part of the 13th and 14th five-year plans, the doc’s imaginative and prescient is for China to maneuver past being the ‘world’s manufacturing unit’, a standing the nation has earned due to its low labour prices and the manufacture of technology-intensive items. China’s Twin Circulation Technique (2020) enhances this concept of a extra economically and technologically unbiased China and seeks to prioritise inner demand as a driver of development (albeit with out the nation turning its again on its export technique).

What makes this try at technological improvement regarding is that the brand new method has gone hand-in-hand with a extra assertive and even coercive method to overseas coverage. In a serious speech delivered on the Hudson Institute on 4 October 2018, Mike Pence (Vice-President beneath the Trump Administration) clarified the US stance: China’s intentions (neither peaceable nor productive) make any industrial management much more harmful, since in the end this interprets into army management.

For China, technological autonomy means above all self-sufficiency within the manufacture of semiconductors, of which the nation is at present the biggest international client (40% of world gross sales in 2021).

Semiconductors are additionally the nation’s greatest import (US$33 billion a 12 months, even better than oil). Made in China 2025 set a goal of assembly 40% of consumption by 2020 and 70% by 2025. Over US$50 billion of funds are earmarked for funding (typically managed by the State) on the nationwide and native ranges, alongside tax incentives, low-interest loans and authorized measures to incentivise native manufacturing of know-how or its acquisition overseas.

Regardless of all this funding, China stays removed from reaching its aims: its market share of the highest tiers of the worth chain (eg, manufacturing and design) has hardly modified (besides maybe for reminiscence chips). Nonetheless, the nation maintains its energy on ATP (the place the agency JCET enjoys a 14% market share).

Obama-era sanctions

It’s usually believed the know-how conflict started beneath the Trump Administration. Nevertheless, its roots return to the Obama presidency, no less than to 2010, when the US awoke from its dream of an more and more democratic China steadily integrating into international financial and political governance. Xi Jinping’s rise to energy in November 2012 was seen as additional proof China that was transferring in the direction of sturdy management.

On this context, in 2015 the Bureau of Business and Safety of the US Division of Commerce, which is answerable for export controls, launched an investigation into ZTE, a big Chinese language telecommunications agency that acted as an middleman within the procurement of US know-how that was being re-routed to Iran and North Korea to evade sanctions. In March 2016 ZTE was added to the US Entity Record, an inventory of firms classed as receiving delicate US items.

New sanctions beneath Trump

ZTE’s US$900 million high-quality for failing to adjust to sanctions on Iran and North Korea was handed down in March 2017, shortly after Donald Trump entered the White Home. Regardless of his many variations with the earlier Administration, Trump shared a mistrust of China (which he blamed for stealing 1000’s of US jobs). Investigations have been launched into Chinese language firms and really quickly one other telecommunications big was within the crosshairs: Huawei. This time, the issue was not solely the evasion of sanctions but in addition the corporate’s dominance of the 5G ecosystem (on which the US lagged behind China and Europe). The know-how, which gives the low latency wanted for functions equivalent to autonomous automobiles and telehealth, additionally has main nationwide safety implications for communications. Whereas Huawei is probably most well-known for its telephones, it additionally manufactures 5G telecommunications gear (base stations and towers). Furthermore, regardless of being a personal firm, there may be little doubt that, if summoned beneath article 7 of China’s Nationwide Intelligence Regulation, it will adjust to any Authorities requests to intercept communications (this level is especially essential when coping with know-how that requires the fixed set up of safety patches).

As Huawei telecommunications gear required US semiconductors, the corporate was added to the Entity Record in Could 2019. Nevertheless, the measure didn’t ship the anticipated outcomes: the US Administration quickly realised that the one semiconductors it had managed to manage have been direct exports from the US, which make up a fraction of world manufacturing (many chips designed by US firms are manufactured in foundries in Taiwan and South Korea).

The issue is that although there are worldwide agreements to manage commerce in twin use items (civil and army) and regardless of the potential for the usage of semiconductors for telecommunications units in cyber warfare (or as an instrument of coercion because of their position in key infrastructure), they’re classed as business items and international locations don’t usually topic them to export management. By prohibiting their export with out altering the worldwide provide chain, the US was really harming the competitiveness of its personal firms. To treatment this case, in August 2020 the nation resorted to an oblique route: the Overseas-Produced Direct Product rule, which topics the abroad manufacture of semiconductors utilizing US units to licences. As US units are utilized by nearly all of the world’s foundries, the rule successfully allowed the US to manage all semiconductors destined for Huawei no matter the place they have been made. Terrified of shedding the fitting to make use of US know-how, the primary international producers fell in line and restricted themselves to promoting 4G chips to Huawei (licences for 5G know-how have been constantly denied).

Nevertheless, the measure had an undesired aspect impact: on the top of the pandemic, when many vegetation have been closed because of lockdowns, many firms, frightened of being sanctioned, started stockpiling semiconductors on a large-scale, aggravating shortage and inflicting costs to rise sharply.

In parallel, China’s army and civil sectors grew to become additional intertwined. Chinese language firms have been inspired to offer know-how for the Chinese language military, blurring the already murky boundary between the civil and army use of semiconductors.

This resulted within the approval of a 3rd package deal of export management measures in 2020, this time centred on SMIC, one of many largest producers on this planet (positioned in Shanghai). The concept was to forestall SMIC utilizing US know-how to fabricate superior chips that might discover their means into the fingers of the Chinese language military.

The know-how conflict beneath the Biden Administration

Whereas formally a lot modified with Biden’s arrival within the White Home, structurally this isn’t the case. Those that believed the brand new Administration would finish Trump’s tariff protectionism and the sanctions on China have been proved unsuitable.

Two pivotal occasions occurred in the summertime of 2022: the primary was the information that, regardless of being included on the Entity Record, SMIC had efficiently produced a highly-advanced-node chip (7nm); the second was the controversial go to to Taiwan by the Speaker of the US Home of Representatives, Nancy Pelosi, to which China responded with a serious army response, producing critical considerations. The occasions dispelled any doubts concerning China’s nationwide safety implications for the US. From autumn 2022 something that might facilitate the event of advanced-node semiconductors in China, superior software program or supercomputers was to be thought of a nationwide safety menace for the US.

On 16 September 2022, Biden’s Nationwide Safety Adviser, Jake Sullivan, delivered a serious speech that modified the nationwide safety aims of export controls. Whereas the outdated goal was to take care of a ‘relative’ benefit over opponents for sure key applied sciences (utilizing a ‘sliding scale’ method to remain a number of generations forward), within the new geopolitical context the target grew to become to take care of ‘as massive of a lead as doable’. In a multipolar world, the sliding scale, designed for the gradual liberalisation of controls on applied sciences as they grow to be mass-market client items (eg, GPS or encryption for cellphones) is just not sufficient: as a substitute, it’s crucial to remain far forward of opponents, no matter the fee.

In sensible phrases, this speech translated into the measures unveiled on 7 October 2022, limiting the manufacture of 4 strategic merchandise in China: advanced-node semiconductors; semiconductor manufacturing gear (of any sort); superior computing capability; and supercomputers. The overarching thought is that US firms and people shouldn’t contribute in any technique to the event of those merchandise by Chinese language amenities.

Determine 3. Timeline of US know-how sanctions on China

Measures Corporations affected Scope
March 2017 ZTE Sanctions
August 2018 Huawei and ZTE Prohibition of the usage of merchandise by the Authorities
Could 2019 Huawei and associates Added to the Entity Record
August 2020 Huawei and associates Overseas-Produced Direct Product rule: prior licence for the usage of US equipment to supply superior chips (<10nm) destined for Huawei
September 2020 SMIC Classed as a army firm managed by the Chinese language Communist Celebration. Prior licence for the provision of know-how
December 2020 SMIC and associates Added to the Entity Record Prohibition of funding in SMIC
October 2022 All kinds of firms Prior licence for the usage of US know-how for manufacturing advanced-node semiconductors, semiconductor manufacturing gear, superior computing capability and supercomputers in China Not solely US firms but in addition US residents forbidden from aiding the manufacture of those merchandise
Supply: the writer.

The measures of October 2022 (which set a one-year transition interval for overseas multinationals that manufacture chips in China, eg, TSMC, Samsung, SK Hynix and Intel) means the Chinese language vegetation can solely use US know-how to supply mature-node semiconductors (>14-16nm). Licences are supplied for particular person amenities, not for firms (this implies the identical firm can have one plant authorised and one other that isn’t; whereas this may make it doable to evade sanctions, the choice of prohibiting all kinds of semiconductors may have induced a serious shock to the worldwide automotive business, given the shortage of mature chips). Along with chips, the measures additionally cowl superior computing capability and supercomputers. Lastly, there may be the event of synthetic intelligence, which, along with knowledge, algorithms and reminiscence, requires individuals, explaining why the sanctions additionally prohibit collaboration not solely with US firms but in addition US residents.

Regardless of their extraterritorial attain, the sanctions are nonetheless unilateral, which can scale back their long-term effectiveness (as the worth chain readjusts). For this reason the Biden Administration is at present making an attempt to persuade different governments to affix it, together with international locations whose firms may present alternate options to US applied sciences (such because the Netherlands and Japan, each of which manufacture equipment and with which an settlement was struck in January 2023). One other instance is the Chip 4 Alliance proposal with Japan, Taiwan and South Korea.

The incentives: the Inflation Discount Act and the CHIPS Act

Having outlined nationwide safety as sustaining ‘as massive a lead as doable’ over its direct competitor, it’s not sufficient for the US to hinder manufacturing utilizing export controls (because the progress made by SMIC clearly reveals). Main funding in know-how can be required. This a part of the equation is addressed by the Inflation Discount Act (extra targeted on the vitality transition however with assist for analysis) and, extra particularly, the CHIPS and Science Act (August 2022), which expressly acknowledges the target of sustaining a aggressive edge in science and know-how within the industries of the longer term, together with nanotechnology, clear vitality, quantum computing and synthetic intelligence.

The Inflation Discount Act contains main tax incentives for R&D, in lots of instances linked to semiconductors.

The CHIPS Act (Creating Useful Incentives to Produce Semiconductors) earmarks US$52.7 billion for US semiconductor improvement, with US$39 billion for manufacturing incentives (together with US$2 billion for mature chips for the automotive and defence industries), US$13.2 billion for R&D and coaching, US$500 million for communications safety and strengthening the worth chain of inputs and a 25% tax break on funding.

The US, which is answerable for round 10% of world semiconductor manufacturing however not one of the most superior chips, is decided to grow to be a world chief.

The response from China and different international locations

The measures adopted by the US have proved controversial world wide. From a authorized perspective, on 15 December 2022 China initiated a WTO dispute grievance on the US sanctions (since they contain export restrictions that aren’t essentially appropriate with the WTO). When it comes to the subsidies beneath the CHIPS Act, whereas the WTO permits common R&D subsidies, hyperlinks to particular sectors or nationwide manufacturing are sometimes incompatible. Nevertheless, the difficulty appears unlikely to make a lot progress, not least as a result of the US has made it clear (because of the WTO decision in December 2022) that it’s going to not permit any organisation to outline what constitutes ‘nationwide safety’.

Multilateral points apart, it’s clear that China and the US have accelerated a harmful subsidy race with unpredictable penalties.

On this context, it’s not shocking that different international locations have additionally begun to assist their industries lately, no matter any US cooperation. In Could 2022 Japan agreed to arrange a working group with the US on next-generation semiconductors, with mutual funding and the creation of a joint analysis centre. In Could 2021 South Korea unveiled its plans for US$450 billion of funding as much as 2030 and, in June 2020, Taiwan introduced an annual US$1.3 billion fund to draw overseas funding into the sector, subsidising as much as half of all R&D prices.

Lastly, in December 2022, China introduced a assist package deal for its semiconductor business price over US$143 billion, which takes the type of tax incentives unfold over 5 years, alongside subsidies for manufacturing and analysis.

The consequences of the know-how conflict on the EU

As on different events, the disputes between the US and China have caught the EU off guard. On this aspect of the Atlantic, the talk has been firmly centred on China’s participation within the improvement of 5G know-how (the place, for as soon as, the EU led the US). Nevertheless, it didn’t anticipate the US to embark on a serious spherical of funding subsidies.

The EU, which makes up lower than 10% of world semiconductor manufacturing, has been unable to scale back its dependence (the European Fee has acknowledged that the technique launched in 2013 failed). Manufacturing is concentrated in Germany, France, Italy, the Netherlands, Austria, Belgium and Eire. The EU solely enjoys a place of energy within the segments of fundamental mental property blocks and manufacturing instruments, lagging far behind in different value-added segments. Initiatives beneath the Necessary Initiatives of Frequent European Curiosity programme have largely didn’t ship outcomes, regardless of some efforts within the subject of microelectronics.

In February 2022 the European Fee proposed its personal Chips Act, promising to mobilise over €43 billion to double the EU’s share of semiconductor manufacturing (rising from the present determine of 10% to twenty%). The drive is centred round three priorities: constructing capability in know-how and innovation; safety of provides; and monitoring and disaster response measures.

But, as soon as once more, regardless of the necessity for an pressing response to the US measures (to keep away from the flight of firms throughout the Atlantic), it seems that Member States should not courageous sufficient to simply accept the necessity to finance European public items, by no means thoughts greedy the nettle of agreements to the state assist system. The Dutch Authorities has already rejected the usage of public funds. The outcomes are all too predictable: an underprovision of those public items; and European funding that’s tied to relative fiscal balances and debt ranges and thus inadequate.

Nevertheless, the EU wants to know that the approval of finance and subsidies, that are wanted to make progress on the worth chain, is just not sufficient to make sure success.

China’s monumental funding since 2015 reveals it’s not at all times simple to develop cutting-edge segments. Nor have giants like Intel and Samsung –regardless of all the cash spent– been capable of meet up with TSMC, which has maintained its place of management.

Furthermore, the expertise of Subsequent Technology EU reveals there are structural delays in allocating EU funds, and this may be crucial in a key sector like semiconductors (in distinction to the US, the place credit are virtually automated).


The EU faces an inevitable problem: reply clearly to US measures, accepting that information and cutting-edge know-how are a European public good that may be a prerequisite for future development and competitiveness. Strategic autonomy, which doesn’t solely rely upon the know-how conflict but in addition on the position of different actors concerned within the provide of important uncooked supplies, can’t be allowed to grow to be a meaningless idea. Neither is it logical to deal with sterile debates on prioritising the disciplining of nationwide funds earlier than or after taking over joint initiatives. The controversy on state assist and European financing of innovation (both by a European sovereign fund, as recommended by the President of the European Fee, or by different means) is pressing and might not be postponed.

Semiconductors are the cornerstone of commercial and know-how coverage within the 21st century (together with synthetic intelligence). If the EU doesn’t get up and settle for the time has come to take dangers (albeit with the required situations) and simplify guidelines, will probably be condemned to a harmful strategic dependency over the subsequent few many years.

The writer wish to thank Mario Esteban, Raquel Jorge, Miguel Otero and Federico Steinberg for his or her feedback.

Picture: Silicon foil for semiconductor fabrication of built-in circuits. Photograph: Chormail.