Samsung Electronics and SK Hynix have confirmed upgrade work at their Chinese memory factories, saying equipment installations are being carried out in consultation with the US government. Washington restricts shipments of US chipmaking equipment to China, and the companies did not disclose the full scope of their licenses.

Reuters reported October 21 that Samsung plans to introduce 286-layer NAND at its Xi’an plant, while SK Hynix is moving its Dalian factory toward chips with more than 240 layers. Those production details came from people familiar with the plans. The news agency could not determine how extensively US licenses covered the work.

Samsung said it was complying with US rules and was not expanding production capacity or building new facilities. The Bureau of Industry and Security declined to discuss the companies’ licenses, referring instead to its existing policy.

That policy dates to an August 2025 decision removing license-free equipment access for selected foreign-owned factories in China. The Validated End-User program had allowed participating manufacturers to receive most US-origin goods, software and technology without individual export licenses.

BIS gave former participants 120 days after publication of the rule to obtain licenses. It said it intended to approve equipment exports needed to operate existing factories, but not those intended to expand capacity or upgrade technology. The policy statement does not disclose the conditions attached to any particular company’s subsequent approvals.

NAND flash stores data in solid-state drives, including those used in AI data centers. It is a different product from the high-bandwidth memory attached to AI accelerators. Stacking additional layers allows manufacturers to fit more storage cells into a chip; improving storage density is distinct from increasing the number of wafers a factory processes.

The proposed Chinese processes would remain below a layer count SK Hynix has already put into production elsewhere. The company announced mass production of 321-layer NAND in November 2024, targeting storage for data centers and devices running AI applications.

In that announcement, SK Hynix described a manufacturing process that connects three separately etched sections of the stack. It used a low-stress material to reduce wafer warping and introduced automatic alignment correction. The company said the design improved production efficiency over its previous 238-layer generation.

The equipment restrictions sit alongside separate moves to control AI hardware and technology transfers. Taiwan’s economic affairs minister has outlined plans to criminalize unlicensed exports of restricted AI chips and servers to China, without giving an implementation date. China, meanwhile, has proposed export controls on specified AI technologies; public consultation runs through November 15.

Sources: Reuters, Bureau of Industry and Security, SK hynix

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By the Control Plane Editorial Team