On March 7, 2025, the Center for Strategic and International Studies (CSIS) published a report titled Understanding U.S. Allies’ Current Legal Authority to Implement AI and Semiconductor Export Controls, which examines and compares the current state of semiconductor and artificial intelligence (AI) export controls in the U.S. and its allied nations.
DSET CEO and Head of the Economic Security Program, Jeremy Chih-Cheng Chang, was invited by Gregory Allen, Director of the Wadhwani Center for AI at CSIS, to serve as one of the report’s reviewers, providing editorial recommendations. As the primary reviewer of the Taiwan chapter, Dr. Chang and the DSET team contributed detailed descriptions of Taiwan’s export control framework. “During the drafting process, we found that there is a significant lack of English-language materials describing Taiwan’s export control system. The DSET team dedicated considerable effort to compiling relevant information and explaining it to the CSIS team,” said Dr. Chang.
Key details added by DSET include Taiwan’s competitive edge in semiconductors due to its fully integrated industrial ecosystem; export control regulations covering semiconductor manufacturing technologies at 14nm and below, critical gases, chemicals, packaging technologies, and specialized materials; post-quantum cryptography protections; restrictions under the Act Governing Relations Between the People of the Taiwan Area and the Mainland Area; foreign investment review mechanisms; and tax incentives. These additions helped CSIS present a more comprehensive picture of Taiwan’s evolving export control landscape.
Regarding the significance of the report, Dr. Chang stated, “This report reinforces the policy recommendation that effective export control frameworks must rely on multilateral cooperation. It also systematically organizes the regulatory approaches of different nations, facilitating international collaboration.”
The report highlights that while the most advanced semiconductors designed by U.S. companies still rely on German, Dutch, and Taiwanese technology partners for manufacturing, unilateral U.S. controls alone are insufficient to fully constrain China’s technological development. Research indicates that although U.S. allies generally lack export control mechanisms equivalent to the Foreign Direct Product Rule (FDPR) and the Entity List, they do possess the ability to enforce certain levels of restrictions.
The findings suggest that Taiwan has already implemented specific export control measures targeting China, whereas most other allied nations have not established similar targeted regulations or have yet to publicly clarify their stance. This places Taiwan in a relatively unique position among U.S. allies.
The report concludes with five key recommendations to strengthen the technological blockade against China. First, policymakers in allied countries should leverage existing legal authorities to restrict their citizens from participating in China’s advanced semiconductor manufacturing. Second, export restrictions specifically targeting AI chips and related technologies should be established. Third, allied nations should implement policies similar to the U.S. FDPR to prevent companies from bypassing export controls via third-party jurisdictions.
Dr. Chang emphasized that reforming Taiwan’s export control system in coordination with allied nations remains a key research focus for DSET. The organization continues to engage in discussions with researchers and former officials from Taiwan and the U.S., working alongside strategic partners such as CSIS, RAND, and SCSP. Moving forward, DSET aims to further these collaborations and produce additional research findings.