Nvidia's H200 Export Window: Unlocking Older Chip Access to China Amid Policy Tension

Nvidia appears poised to break through Washington’s export restrictions with a significant policy shift. The U.S. Department of Commerce is moving toward clearing shipments of its H200 artificial intelligence processors to China—specifically units from roughly a year and a half ago, according to Semafor reporting. While these chips represent a substantial upgrade compared to the legacy H20 models previously cleared for the Chinese market, they fall short of Nvidia’s latest generation technology.

The semiconductor giant views this development favorably, positioning the decision as beneficial for American manufacturing competitiveness and domestic employment. Commerce Secretary Howard Lutnick indicated last week that final authorization rests with President Trump, signaling that geopolitical considerations remain central to these decisions.

Congressional Opposition Intensifies

The potential approval directly contradicts growing bipartisan resistance in Congress. On December 4, Senators Pete Ricketts and Chris Coons rolled out the Secure and Feasible Exports Chips Act, which would implement a 30-month moratorium on export licenses for advanced AI chips destined for China. The measure has yet to secure a voting date, leaving its trajectory uncertain.

The Trump Administration’s Shifting Stance

The current proposal reflects a broader pattern of policy volatility under the Trump administration’s semiconductor export framework. In April, new licensing requirements emerged for AI chip exports. Within weeks, officials reversed a Biden-era regulation. By summer, senior officials floated a novel approach: permitting exports if Washington could claim 15 percent of revenue from China-bound chip sales—essentially weaponizing semiconductor technology in trade negotiations.

China’s Market Reality

The landscape on Beijing’s end has already shifted dramatically. In September, China’s Cyberspace Administration issued restrictions preventing domestic corporations from purchasing Nvidia processors, forcing a pivot toward domestically developed alternatives from Alibaba and Huawei. This regulatory move, combined with export limitations, has fundamentally altered the competitive dynamics of the AI chip market.