Chinese firms looking to place orders may therefore find themselves at the back of the queue. Alibaba and ByteDance are both thought to be “keen to place large orders” should Chinese regulators give them the green light to do so. However, the companies are concerned about supply and are said to be actively seeking clarity from Nvidia on this.
If all this goes ahead, the H200 would reintroduce training-scale compute capacity to Chinese AI developers after a long period of reliance on repurposed hardware and grey-market acquisitions . The chip delivers roughly six times the performance of the H20 and approaches the capabilities of Nvidia’s H100, which has been banned from China since late 2022. Unlike most Chinese accelerators, the H200 supports Nvidia’s CUDA software ecosystem, simplifying model porting and cluster integration.
Ultimately, Nvidia is unlikely to resume large-scale H200 production unless it receives strong approval from both U.S. and Chinese regulators, and equally strong demand from Chinese customers. The chip is already considered a transitional product within Nvidia’s roadmap , with Blackwell occupying the top end of the current generation and Rubin expected to extend that lead in 2026.
U.S. officials have attached a number of technical and procedural conditions to the H200 export approval. Each unit must be shipped to the U.S. before entering China, creating a traceable logistics trail that allows U.S. Customs and Commerce Department inspectors to verify compliance. Nvidia has also introduced optional location-verification software that can confirm whether a chip is operating in an authorized geography.
The system uses a combination of secure telemetry and latency-based network checks to determine the approximate location of a GPU within a customer’s infrastructure. While not mandatory — at least not yet — the feature has been privately demonstrated as a tool for audit and compliance. Nvidia has framed the technology as a data center management solution rather than a surveillance system, and the company has emphasized that it cannot remotely deactivate or control chips in the field.
Nonetheless, the software has raised concerns in Beijing, with the Cyberspace Administration of China questioning whether the technology constitutes a backdoor or allows external access to sensitive operations. Nvidia has stated that the system, which will first be made available on Blackwell chips, cannot be used for eavesdropping and does not transmit any user data to third parties. It remains to be seen whether Chinese buyers will enable the feature or attempt to route around it using intermediaries.
The compliance measures reflect a broader concern that export controls, while useful on paper, have proven difficult to enforce. We’ve seen several examples of banned Nvidia GPUs like the A100 and H100 appearing in the likes of Chinese university research and start-up product documentation since their respective bans. Many of these were likely acquired through grey-market channels or indirect resellers in third countries.
The U.S. Justice Department has already indicted several individuals involved in smuggling high-performance Nvidia chips to China in violation of export rules. Cases are ongoing in multiple districts, and officials have signaled that enforcement will intensify as more tracking capabilities become available.
The approval of H200 exports arguably represents a concession rather than any long-term structural change in U.S. policy. The Biden and Trump administrations have consistently maintained that the U.S. must retain leadership in AI hardware and semiconductor manufacturing. The H200, while advanced, is no longer Nvidia’s leading product, and allowing access to it gives Washington a tool to slow China’s push for independence without giving up the top tier of its technology stack.
From Beijing’s perspective, the decision provides short-term relief. AI developers can resume training at scale using supported hardware and familiar toolchains, but the long-term imperative remains unchanged. China continues to invest in domestic foundries, chip design houses, and packaging capacity. Huawei is expanding its Ascend production targets, and other firms are attempting to design new architectures that bypass the limitations of restricted U.S. IP.
The H200 will be welcomed by those who can access it, but the approval comes with strings attached and no guarantee of duration. Chinese firms must navigate what could be a complex approvals process, limited supply, and reputational risk. Nvidia, meanwhile, must manage Washington’s expectations while preventing its technology from slipping beyond authorized use.
The success or failure of this arrangement may determine how future export rules are written. If H200 exports proceed smoothly, it could serve as a model for calibrated engagement, but if compliance breaks down or political conditions shift, the window may close just as quickly as it opened.
Luke James Social Links Navigation Contributor Luke James is a freelance writer and journalist. Although his background is in legal, he has a personal interest in all things tech, especially hardware and microelectronics, and anything regulatory.
Key considerations
- Investor positioning can change fast
- Volatility remains possible near catalysts
- Macro rates and liquidity can dominate flows
Reference reading
- https://www.tomshardware.com/tech-industry/semiconductors/SPONSORED_LINK_URL
- https://www.tomshardware.com/tech-industry/semiconductors/us-eases-nvidia-export-restrictions-h200-cleared-for-china-under-tight-controls#main
- https://www.tomshardware.com
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Informational only. No financial advice. Do your own research.