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China AI Chips: GP10 Danger!

BIS guidance warns: Using Huawei AI chips may trigger EAR violations—even outside the U.S.

 

If you're in Export Control, Compliance, or handle dual-use goods, take note. On May 13, 2025, the U.S. Bureau of Industry and Security (BIS) released guidance that hits at the heart of global AI development. It names specific advanced-computing integrated circuits (ICs) from China as export control risks—particularly those from Huawei. This isn't just a U.S. issue. Companies in the EU, UK, and globally could fall into the General Prohibition 10 (GP10) trap without even knowing it.

 

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Key Questions Covered in This Blog

  • What chips did BIS identify as high-risk and why?

  • What is ECCN 3A090, and how does it apply to Huawei’s AI chips?

  • What exactly is General Prohibition 10 (GP10) under the EAR?

  • How can companies be held liable—even outside the U.S.?

  • What’s the “safe harbor” exception BIS provides?

  • What are the compliance steps businesses must take now?

 

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“General Prohibition 10 is the EAR’s silent tripwire. You don’t need to pull the trigger to be caught—you just need to touch the wrong item.”Arne Mielken, Managing Director, Customs Manager Ltd

 

Abbreviations Used in This Blog

  • BIS – Bureau of Industry and Security

  • EAR – Export Administration Regulations

  • ECCN – Export Control Classification Number

  • GP10 – General Prohibition 10

  • IC – Integrated Circuit

  • PRC – People’s Republic of China

 

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What chips did BIS identify as high-risk and why?

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