The most potent criticism of the U.S. chip controls wasn't flawed strategy, but the chronic underfunding and limited capacity of agencies like the Bureau of Industry and Security (BIS) to effectively enforce complex export bans against determined adversaries.

It's a common error to conflate the CHIPS Act and the October 2022 chip controls. The CHIPS Act was a legislative effort for domestic manufacturing resilience. The executive export controls were a separate national security policy focused on denying China access to high-end compute for military applications.

Key departments like Commerce have conflicting mandates. The Commerce Secretary's primary goal is to promote U.S. business abroad, which structurally disincentivizes them from implementing tough export controls that could harm those same businesses, thus undermining national security objectives.

The U.S.-China Commission proposes consolidating disparate economic tools like export controls into a single entity. This would prevent critical decisions from languishing at mid-levels within conflicted departments and create a single forcing function for action, reducing the need for constant NSC intervention.

A small team in the Biden White House successfully implemented crucial export controls on semiconductor technology before ChatGPT's release made AI a mainstream obsession, allowing them to act proactively rather than reactively.

Contrary to their intent, U.S. export controls on AI chips have backfired. Instead of crippling China's AI development, the restrictions provided the necessary incentive for China to aggressively invest in and accelerate its own semiconductor industry, potentially eroding the U.S.'s long-term competitive advantage.

The U.S. reactively chases news headlines (like rare earths) without a rigorous framework to identify its most critical dependencies. Policymakers have not prioritized whether to secure wartime supply chains or mitigate China's leverage over consumer goods that could spark domestic political crises.

The U.S. government identified a critical loophole allowing Huawei to acquire advanced High Bandwidth Memory (HBM) but waited nearly a year to close it. This bureaucratic delay, from February to December 2024, provided a significant window for China to stockpile essential components, undermining the broader export control strategy.

Major US technology policies, such as the October 2022 semiconductor export controls, are not sudden shocks. They are often telegraphed years in advance through influential government commission reports, like the one from the National Security Commission on Artificial Intelligence (NSCAI), which provided the blueprint for these actions.