An analysis of the securities registration statement submitted by CXMT for a listing on Shanghai's STAR Market found no content related to capital expenditures for high bandwidth memory (HBM). China's drive into HBM, cited as a mid- to long-term threat to Samsung Electronics and SK hynix, is not materializing in this large-scale investment plan, at least for now.
On the 8th, semiconductor market research firm SemiAnalysis said in a report analyzing the original text of CXMT's securities registration statement that "the HBM facility investment project was omitted, and there was no mention of HBM at all." The core of this initial public offering (IPO) is strengthening the manufacturing and technology base for commodity DRAM, and it does not include a funding commitment for near-term HBM capacity expansion.
In the documents CXMT actually submitted, the entire 29.5 billion yuan (5.7 trillion won) in proceeds was allocated to upgrading commodity DRAM production lines and next-generation DRAM research and development, and there was no separate HBM project item.
In the second half of last year, CXMT reportedly built dedicated HBM packaging equipment and supplied samples to Huawei, spreading concern at home and abroad about its entry into the HBM market. But with HBM missing from this large-scale investment disclosure, assessments are emerging that the credibility of a "China-led HBM blitz" scenario is weakening.
The reason the market is watching CXMT is simple. The HBM market, a high value-added memory product, is effectively an oligopoly of Samsung Electronics, SK hynix, and Micron. If a Chinese company enters, there are concerns that pricing power and supply chain dynamics could be disrupted. This disclosure is read as evidence that grounds to bring that timeline forward are still insufficient.
In terms of actual production capacity, CXMT's HBM transition also appears to remain in an early stage. SemiAnalysis estimated that by the end of 2025, of CXMT's total capacity (about 265,000 wafers per month), around 5,000 wafers would be allocated to HBM, less than 2% of the total, and projected a gradual increase to 30,000 wafers by the end of 2026 and 55,000 by the end of 2027. The securities registration statement also disclosed that 99% of 2025 revenue came from commodity DRAM products such as PC and mobile, in line with this trend.
A gap is also evident in technological maturity. A semiconductor equipment company official said, "We estimate that CXMT's HBM3 (fourth-generation HBM) 8‑high product, believed to be under development now, has an overall Production yield of around 25%," adding, "At this point, given the yield and quality, supplying outside China will be difficult." The major customers listed in the securities registration statement (Alibaba Cloud, Tencent, ByteDance Ltd., Lenovo, Xiaomi, etc.) are all existing commodity DRAM and DDR5 clients, and no separate HBM-related contracts were specified.
Barriers to CXMT's aggressive HBM capital spending include the technical difficulty of through-silicon via (TSV) stacking yields, a core HBM process, and restricted access to advanced equipment due to U.S. export controls. As CXMT faces scrutiny from the U.S. Department of Defense and the Department of Commerce, there are also concerns that explicitly stating an HBM investment plan for AI accelerators in the securities registration statement could provide grounds for additional restrictions.
Some, however, suggest that HBM investment funds may have been raised through channels separate from this IPO's proceeds, such as state-backed funds or local government financing. The interpretation is not that there will be no HBM investment at all, but that it is not the use of these proceeds.
A semiconductor industry source familiar with China said, "There are even projections that by 2027 or 2028, HBM capacity could expand more than tenfold from current levels," but added, "For now, it is premature to say CXMT's HBM drive has fully begun, and the pace of IPO fund deployment and the direction of government policy will be the key variables."