Compute gets a numeric ceiling
In October 2022 the U.S. Bureau of Industry and Security put the accelerator on the export control list by two numbers taken together: a transfer rate to other chips of 600 gigabytes a second or more and, at the same time, a bit length times processing performance of 4800 or more. Separately it closed off equipment for logic below 16/14nm, DRAM below 18nm and NAND at 128 layers or more.
Why it matters
For the first time access to compute is limited not by a list of companies but by a threshold in technical units. That makes the rule automatic - it catches anything that crosses the line, including what has not been designed yet - and at the same time open to working around, because a product can be designed to sit under it. The atlas showed the consequence of this in 2026 without showing the cause.
There are three dates here and they differ. The press release and the first instructions are 7 October 2022: semiconductor manufacturing equipment and a new section on end use. 12 October: the restriction on U.S. persons, who now need a licence to support production at a fab in China making logic below 16/14nm, DRAM below 18nm or NAND at 128 layers or more. 21 October: ECCN 3A090 itself, the accelerator threshold. All of it was published in the Federal Register on 13 October as 87 FR 62186. The decisive word in 3A090 is "and", not "or". The entry requires an aggregate bidirectional transfer rate of "600 Gbyte/s or more" AND any of four sub-criteria, each a bit length per operation times processing performance in TOPS "of 4800 or more". The research report this record was made from had "or" there, and called the 4800 a number of bits. The difference is not terminological: it is the conjunction that made it possible, the following month, to build a part that computes as fast and talks more slowly. NVIDIA reads it the same way in its quarterly report - the requirements reach circuits achieving "both peak performance and chip-to-chip I/O performance" at A100 level. The country chart for 3A090 names one country: China. The expansion to forty-odd jurisdictions comes a year later.