Exports to China of Nvidia's H200 artificial intelligence (AI) chip have now run into a new hurdle: a shortage of memory chips.
Bloomberg reported on the 16th that U.S. House Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party Chairperson John Moolenaar (R-Mich.) wrote to Minister Howard Lutnick of the Commerce Department, calling a shortage of DRAM—essential for AI accelerators—an "immediate challenge" under the new export license conditions.
Moolenaar said in Seohan Engineering & Construction that "because of severe supply constraints, chips equipped with HBM3E (5th-generation high-bandwidth memory) heading to China represent the opportunity cost of HBM3E that U.S. customers could use."
Amid the memory chip shortage, the interpretation is that if chips equipped with HBM3E are exported to China, the available volume of HBM3E for U.S. customers will shrink by that much.
The U.S. government recently completed procedures to revise the rules for exporting the H200 to China.
After individual reviews, the H200 can be exported to China, but certain conditions must be met to obtain approval.
The chip must be commercially available for purchase in the United States, and exporters must prove that there is sufficient domestic supply of the chip and that producing versions for export to China has not impeded production of other products for U.S. consumers.
Moolenaar asked the Minister Lutnick to brief the Select Committee on the Strategic Competition this month by the 25th on the matter.
High-bandwidth memory (HBM) is produced by three major memory makers—SK hynix, Samsung Electronics and U.S.-based Micron—and with demand surging amid the recent AI data center boom, concerns about shortages have been mounting.
Nvidia CEO Jensen Huang, at "CES 2026," the world's largest consumer electronics and information technology (IT) show held earlier this month, acknowledged the memory chip shortage but said Nvidia would not be affected because it is the sole buyer of HBM4, the next-generation HBM.
The H200 is widely used to develop and run large language models (LLMs) and image-generating AI. Its export to China had been banned but was allowed after President Donald Trump reversed course early last month.
When news broke last month that H200 exports would be allowed, Chairperson Moolenaar strongly criticized the move in Seohan Engineering & Construction sent to Minister Lutnick, saying, "Allowing China to purchase millions of chips more advanced than its domestic ones would undermine President Trump's efforts to maintain U.S. dominance in the AI industry."