"In our nation's 248-year history, there has never been an individual who is a greater threat to our republic than Donald Trump. He tried to steal the last election using lies and violence to keep himself in power after the voters had rejected him.
He can never be trusted with power again.
As citizens, we each have a duty to put country above partisanship to defend our Constitution. That is why I will be casting my vote for Vice President Kamala Harris."
Today’s breakdown is authored by “Lithos Graphien,” an anonymous contributor with decades of experience in the lithography industry.
Printed Electronics and the Age of AI
65 years ago, Robert Noyce of Fairchild Semiconductor envisioned a way to make complex electronics using a printing process known as semiconductor lithography. Thus, the monolithic integrated circuit — or microchip — was born.
Not long after, Noyce co-founded Intel with Gordon Moore, who famously observed in 1965 that the number of transistors (electronic switches) on Intel’s microchips doubled every four years because of improvements in this printing process.
Moore’s Law holds to this day, with smaller and smaller circuit parts printed to pack more computational power into each new chip. In the near future, chips the size of your fingernail will contain an astronomical 100 billion transistors.
For this reason, a nation’s lithography capabilities determine the power of the semiconductors they can produce. That’s why lithography tools have been a key focus of US export controls.
Semiconductor Lithography Is at the Heart of the US-China Chip War
The US Department of Commerce — along with allies in the Netherlands and Japan — has so far issued two rounds of export controls aimed at limiting China’s lithographic capabilities. We summarized the first two rounds of export controls in this article.
Chinese companies like SMIC, however, have still managed to produce advanced semiconductors despite these controls. As another October approaches, which is Commerce’s favorite time of year to issue these updates, we can once again expect some type of action on lithography.
This week, confidential sources told Bloomberg that the Netherlands intends to let the export licenses for ASML’s scanner parts expire at the end of the year, bowing to pressure by US Commerce.
ASML is the leading provider of lithography tooling, and their most advanced scanners have already been banned from export to China. The problem, though, is that Commerce took a number of years to enact these restrictions, and a large fleet of advanced tooling is already installed in China.
The chart below summarizes the machines made by ASML that are currently allowed or banned from export to China.
The key performance metric that Commerce uses to determine the law is called overlay — the ability of the machine to overlay two circuit patterns. Overlay is a measure of alignment error, and with today’s chip parts printing features on the tens-of-nanometer scale, overlay makes the difference between printing a mature node chip (>28nm) or an advanced one (<28nm). Each new generation of ASML scanners made incremental improvements in overlay.
Another improvement metric is throughput — the number of wafers per hour that can be processed through the tool. This doesn’t enable a new chip technology, but it has a considerable impact on the value of a scanner. Commerce has thus far made restrictions only on overlap, not throughput.
So what will happen next year for a Chinese fab using these tools?
First, note that no Chinese company can run these tools in secret. Every tool is accounted for by ASML and monitored by the factory. It should be fairly straightforward for ASML to segregate the export of parts for the blocked tools and the allowed tools. Most of the spare parts will be common between the blocked and allowed tools, so knowing where the parts are going will be key for enforcing the law.
Second, ASML’s immersion scanners are known for their reliability. They can often run for months at a time without maintenance, and for a much longer period before requiring a spare part.
These banned tools will be operational well into 2025 and perhaps beyond. But on a long-enough timescale, each of these tools will eventually become an idle boat anchor without spare parts.
So Chinese companies may attempt to stockpile key parts for these tools over the next four months.
Third, there is some confusion regarding whether ASML can or will block the servicing of these tools. The Dutch issue licenses only for physical goods, not technical services, so there is technically no expiration date on equipment servicing. Even so, it’s possible that ASML will stop servicing the banned tools anyway, because it’s in the spirit of what Dutch Commerce intended.
Uncharted Territory
The Dutch government’s move — letting export licenses for ASML’s scanner parts expire — at the request of US Commerce is unprecedented, in that Chinese companies legally purchased the machines under the assumption that ASML would support them for the lifetime of the tool. ASML still supports scanners they made thirty years ago. Impacted Chinese chipmakers will definitely respond through any legal channels possible. But if that fails, what is their contingency plan? What will ASML do to preserve revenues from their lucrative business in China?
The Nvidia model
Nvidia has been the focus of US Commerce as well. To limit China’s AI capabilities, Nvidia’s GPUs are limited based on their performance specifications.
In response to each new Commerce rule, Nvidia designed a special chip for the Chinese market that met the throttle specifications. ASML can take a similar approach — ie. they can meet the requirements by throttling the overlay performance on a blocked tool inside China to the required value of 2.5nm SMO. That would be both in their interest and in the interest of Chinese chip companies.
How would scanner overlay throttling work?
Over the years, many of the overlay improvements in ASML’s scanners were driven by software. That could include a new correction algorithm or a way to take more measurements. For this reason, the most likely tool downgrade option will be a software update pushed out remotely from ASML’s factories. This accomplishes a few goals:
It’s a relatively cheap, fast way to keep China’s fleet of immersion scanners running and earning money. This will be important if the legal battles are drawn out over a long period of time.
In the event that Commerce relaxes some of the restrictions under a new administration, the performance can be updated to the new overlay targets to improve tool performance again.
The blocked tools have the added value of improved throughput — which is not under any restriction — to maximize tool value.
And the tool will retain its resale value to a customer outside of China. If SMIC wanted to sell them to TSMC, for example, a similar software update could return it to advanced performance.
What are the bigger implications for China?
These restrictions will make it harder for Chinese companies like SMIC to produce a 7nm or 5nm chip. Commerce’s intent to limit China at the 14nm node will likely be fully enforced. And without further policy intervention, China will likely accelerate production of mature chips, advancing toward becoming the world’s top producer.
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To discuss the post-election future of US competition policy, ChinaTalk interviewed Peter Harrell and Nazak Nikakhtar.
Nazak served in the Trump administration after a long career as a civil servant, where she was instrumental in shaping the Commerce Department’s work on China, first at the International Trade Administration and later leading the Bureau of Industry and Security. Peter worked in the Biden administration on the National Economic Council and National Security Council, focusing on international economics, export controls, and investment restrictions.
We discuss…
The role of the executive in setting the industrial policy agenda
Leadership shortcomings in the Biden and Trump administrations
Competition with China — bipartisan consensus, bureaucratic inertia, and strategies to stop wasting time.
Advice for America’s next president, from export controls to pharmaceutical decoupling and alliance management
Creative approaches to supply chain resilience
Listen on Apple Podcasts:
Listen on Spotify:
Optimizing Presidential Powers
Jordan Schneider: Let’s start by discussing the role of presidents in policymaking. I’m curious about your perspectives on the transmission belt of policy directives, both up toward the president and down from the president. Nazak, would you like to begin?
Nazak Nikakhtar: Certainly. The transmission belt process varies depending on the class of decision, which is determined by market impact and geopolitical significance. Career officials in the U.S. government understand the rules and protocols, working with interagency partners to evaluate necessary actions.
Then, if this is something they need to elevate for additional geopolitical or economic reasons, decisions are made about whether to seek interagency consensus at the assistant secretary, undersecretary, deputy, or cabinet level. All of this is coordinated through the National Security Council. Sometimes, directives come from the president. It’s a two-way street — more frequently bottom-up, but occasionally top-down.
Congress’s bipartisan push to regulate TikTok is “heartwarming,” Nazak Nikakhtar said. Source: CSpan.
Peter Harrell: Building on that, in both the Trump and Biden administrations, the president ultimately set the strategic direction for the administration on issues like China policy. For example, the president decides whether to pursue de-risking across many sectors of the U.S.-China economic relationship, or whether to focus on a select subset. They determine the scope of prohibitions on U.S. investment in China.
Do we want a wide sweep of prohibitions on US investment in China, or do we want a more targeted set of prohibitions?
Given the diverse voices within an administration and in Congress, it is up to the president to establish the strategic direction. This includes defining focus areas in the relationship, determining the breadth of approach, and envisioning a desired endpoint state for the short and long term.
This strategic direction allows agencies to utilize their tools to advance these goals. However, some individual cases and tactical decisions must also reach the president’s desk due to their significance or statutory requirements. For instance, major decisions like sanctioning or placing one of China’s largest companies on the entity list should involve presidential approval.
In the case of CFIUS, the investment screening process, only the president has the statutory authority to block a transaction. While the CFIUS committee might be able to persuade parties to abandon a transaction, the legal authority to block it rests with the president.
Generally, I’d encourage presidents and their senior staff to focus on strategic priorities rather than weighing in on every sanction against mid-level corporate officials or government bureaucrats. However, there are significant individual decisions that require presidential involvement.
Nazak Nikakhtar: I’d like to add that recent administrations haven’t excelled at providing granular direction. They often set high-level strategies like deterrence, technological superiority, military preparedness, and working with allies, but stop there. This leaves federal agencies to their own devices to interpret and implement these strategies, which is problematic.
To effectively implement these strategies, more specific guidance is needed from the top. What does deterrence look like in practice? What are the focus areas for achieving technological superiority? Which tools should this administration leverage to reach these goals? This level of detailed direction needs to come from the White House, starting with leadership. I haven’t seen this kind of specific guidance trickle down over the past 20 years, which would empower agencies to execute their strategies confidently. Without it, everyone is left in limbo, trying to determine the right course of action.
Jordan Schneider: Peter, it sounds like you might disagree. Let’s explore this further. Why are you skeptical of senior leaders getting more operational or tactical in their prescriptions?
Peter Harrell: I’m not sure I disagree. The president should not just set overarching priorities but also provide direction one or two levels below that. For example, with inbound investment screening, the president should decide whether to focus primarily on technology investments, include supply chain investments, or aim to restructure the entire investment relationship.
This level of strategic guidance from the top is crucial, but it’s different from bringing a list of 600 Chinese companies to the president for individual decisions. It’s about setting the overall direction and scope without getting bogged down in minutiae.
Nazak Nikakhtar: I agree. For instance, regarding technological superiority, the president should specify which legal authorities to leverage, such as export controls, outbound data restrictions, or capital flow restrictions. This level of prescriptive guidance is crucial for federal agencies.
That is done now in some limited respects, but we need a more comprehensive, implementable grand strategy that provides better direction to federal agencies. I’m tired of reading endless pages from think tanks and government sources that merely state what we already know. We need to focus on how we’re going to achieve our goals.
Are we going to use export controls aggressively? Is it the small yard, high fence? Are we going to make the yard a bit bigger, considering all the stories we’re seeing about circumvention? What do sanctions on China need to look like?
Peter is right that we don’t need to delve into the granular details of chip performance, but we do need to decide whether we’ll use export controls aggressively, define the scope of our approach, and identify specific sectors to target.
We often react rather than proactively implementing a comprehensive strategy. Federal agencies need clear direction to avoid wasting time.
We no longer have the luxury of time when it comes to China. We’ve already spent two decades transferring our technology, supply chains, and workforce to China, weakening our industries.
Bipartisan Boondoggles and Institutional Imprinting
Jordan Schneider: Nazak, you’re arguing that progress stalls without clearer strategic and operational-level direction, correct? What are the opposing forces from a bureaucratic and organizational collaboration perspective that create a bias toward inaction?
Nazak Nikakhtar: That’s an excellent question, and I’d like to hear Peter’s views as well. For the better part of the last 20 years, federal agencies have been indoctrinated with the idea that globalism is inherently good. To be clear, the alternative to globalism isn’t protectionism — it’s about identifying who might distort the global trading system and adjusting our trade relationships accordingly.
The prevailing notion was that we didn’t need to worry much about CFIUS, trade restrictions, or export controls because promoting trade was supposed to be universally beneficial. Around 2015-2016, America had a wake-up call, realizing this approach to China wasn’t working in our favor. The gears started turning in the other direction, but the federal bureaucratic system had been entrenched in this philosophy for two decades.
Career-level officials had long believed their primary purpose was to promote exports, including technology exports. It’s challenging for these individuals to shift their thinking after such prolonged indoctrination. Additionally, there’s enormous industry lobbying pressure. While industry will always advocate for its own interests, it’s the role of federal regulatory bodies to understand that they need to regulate. They should listen to industry perspectives but not always accept them as gospel, instead conducting their own due diligence.
Because the bureaucratic system has been conditioned to believe that industry is always right and that promotion should take precedence over protection, it’s been difficult to shift course. This explains why we’re seeing a narrow, middle-of-the-road approach. We’re making changes, but cautiously, to avoid too much disruption.
While it’s true that our economies are now globally intertwined and detangling them will require effort, we need to be clear about our objectives. What does “de-risking” mean in practice? Are we focusing on specific sectors? Are we aiming for gradual decoupling from distorted actors over time? Federal agency workers lack this level of clarity to understand how they need to shift their mindset, which is crucial for effective implementation.
Jordan Schneider: Part of the reason you don’t get that clarity from the White House is because cabinet members might disagree on what those answers are. We’ve seen this in both the Trump and Biden administrations, and throughout American history. Is it even realistic to expect the kind of harmony you’re hoping for, given that cabinet members are often ambitious individuals with their own ideas?
Nazak Nikakhtar: This is where direction needs to come from the president. It was disappointing in the Trump administration to have cabinet members constantly fighting over issues. I suspect this happens in every administration, but that’s when you need executive leadership to step in and provide clear guidance.
For example, regarding CFIUS — if Chinese laws state that they won’t comply with U.S. laws, should we believe any Chinese company will adhere to a mitigation agreement? Perhaps a president should declare that we should lean towards banning or divestment when Chinese FDI transactions are undergoing CFIUS review.
You can’t just leave cabinet members to duke it out. A president should try to appoint like-minded cabinet members to the extent possible. While you don’t want yes-men all the time, ultimately, you want to select a group of cabinet members who understand your objective and will help you achieve it. They may have differences in approach, which is healthy, but you can’t have cabinet members who fundamentally disagree on the ultimate objective, which we see all too often.
Peter Harrell: I was actually going to take it in a slightly different direction. While it’s not inappropriate for cabinet members to have different views — you probably don’t want everyone around a president to have exactly the same perspective — I very much agree with Nazak that the president ultimately needs to make decisions. The president should hear diverse voices among their advisors on strategic directions but then decide, “This is where I want you to go,” and everyone should align with that decision.
The other crucial aspect is that cabinet members need to work together on implementing effective policy, especially in our complicated relationship with China. To compete effectively, we increasingly need to leverage different types of regulatory tools, policy instruments, financial mechanisms, and diplomatic approaches that are spread across various departments. We need to get them working together to achieve shared goals set by the president.
For example, earlier this year, the U.S. Coast Guard issued a directive making it harder for American cargo ports to buy new cranes from Chinese companies. While China dominates this market, these cranes pose significant security risks as they track incoming cargo and can send that data back to China.
Simultaneously, the administration found funding from the bipartisan infrastructure law to encourage a Japanese cargo crane construction company to set up facilities in the United States, building domestic capacity over the next couple of years.
This demonstrates how you need to combine security measures with economic alternatives, pulling together tools from entirely different departments like the Coast Guard and the Department of Transportation. Cabinet members need to be strategically aligned and direct their officials to collaborate across these different tools to achieve the real-world outcomes we want to see.
Nazak Nikakhtar: Ideally, the president would set the stage by instructing every cabinet member to identify all tools in their arsenal to deter China’s ambitions in the Indo-Pacific. They would request reports on achieving technological superiority, augmenting military and related supply chain preparedness and capacity, and improving integration with allies while reaching out to countries where China has infiltrated. Simply increasing appropriations from Congress is not the solution, as money is limited. The president should have the National Security Council and National Economic Council evaluate these strategies to determine if they align with the overall vision or require adjustments.
Currently, we lack such clear directives from the executive branch. Our approach is disorganized and policies often seem random. There’s no clear long-term strategy, resulting in a haphazard and reactive approach. We cannot win this strategic competition or race with China if we continue in this manner. China is extremely organized, and we must step up our game, particularly in terms of organization within the executive branch.
Stepping on the Gas in 2025 总统加油⛽️
Jordan Schneider: Peter, you’ve seen some Biden administration reports, such as those on supply chains. I read them and thought they were fine, maybe the classified versions were better, but there’s still a long way to go in tackling these issues.
The citations in the supply chain reports were largely from industry sources rather than independent government research.
This demonstrates a lack of institutional memory and expertise in addressing these questions. What are your thoughts on improving the executive branch’s report-to-policy pipeline?
Peter Harrell: There are a couple of factors that make for an effective government report or policy strategy that actually gets implemented rather than shelved.
Obtaining buy-in during the report’s development is crucial. While the president can set direction and instruct cabinet agencies, when it comes to granular decision-making by mid-level career officers, you need their buy-in to the overall vision. An effective report should be developed in a way that garners support from assistant secretaries and undersecretaries, who can then push their teams to execute the report’s direction.
Continuity among officials working on execution is important. While administrations experience turnover, some continuity is necessary. Additionally, the people who put the report together should remain focused on execution rather than moving on to unrelated areas.
The 2021 supply chain initiative launched by President Biden laid out a vision to build resilience in American supply chains across four sectors — semiconductors, large-capacity batteries for vehicles and grid storage, critical minerals, and pharmaceuticals/APIs.
Progress has been quite good in semiconductors and batteries, with significant movement through the Inflation Reduction Act, the Department of Energy’s loan program office, and international efforts to source critical minerals.
But critical minerals have seen mixed progress. This area would benefit from stronger executive leadership, because we need a huge amount of minerals going forward for green energy, for defense, and for industrial applications. But getting things permitted here in the United States is incredibly painful. There are a lot of constituencies that don’t want to see new mines permitted
It would be great if the executive would step in and say, “We hear you that the mine needs to be environmentally sustainable. But also, we actually need to build a mine.”
Pharmaceuticals and APIs have seen the least progress, partly because the administration was initially busy focusing on COVID-related issues.
Moving forward, regardless of who is in office, there seems to be bipartisan consensus on the need to make progress on pharmaceuticals, as current efforts have been insufficient.
Nazak Nikakhtar: The Biden administration correctly identified key sectors to focus on initially. However, I have concerns about the approach. If I put my economist hat on, many solutions were carrot-oriented. While I support industrial policy and investments to catalyze critical manufacturing capacity quickly, we face a significant challenge — industries are hesitant to invest due to concerns about China’s ability to underprice their products.
Unless we signal strongly to these industries that we will protect them from China’s predatory pricing once they are operational, I fear some industries won’t grow as quickly as needed, and others may not grow at all. The June 2021 supply chain report should have been more prescriptive, stating that we would not only fund industry growth and provide tax cuts but also offer necessary price protections to ensure healthy growth.
Regarding critical minerals, while international agreements are beneficial, we still lack commercial processing capacity. We’re setting up supply chains that don’t yet exist. We need to focus on building critical mineral capacity. Some permitting issues could be resolved with common-sense approaches, such as using third-party validators to assess whether projects meet or exceed environmental standards, allowing projects to proceed while awaiting full agency review.
We must think creatively about solutions to move faster in this race against China. It’s crucial to have both carrots and sticks — incentives for good actors and deterrents against predatory actors and non-market economies. This balanced approach is necessary to protect the growth of our supply chains and those of our allies.
Peter Harrell: I agree with Nazak’s macro point that the successful growth of strategic industries in the US and with our Western allies requires consideration of both production incentives and demand-side factors. If we invest in critical minerals processing plants or legacy semiconductor plants in the United States, but China heavily subsidizes their plants and floods the market, making our plants economically unviable, our industrial policy will fail.
Looking back at the 1980s and the Reagan administration’s focus on semiconductors, they employed both incentives through SEMATECH and work with semiconductor companies, and also pushed the Japanese hard to prevent dumping in our market and ensure their market was open to the US. For a successful critical minerals or legacy semiconductor industry here, we need both positive incentives and barriers such as tariffs or other restrictions to prevent Chinese production from undercutting the market for the plants we’re trying to build. Pairing incentives with market protection or demand-side measures is essential.
Alliance Management and the Costs of Decoupling
Jordan Schneider: There are economic trade-offs involved in all of this. For example, a recent report showed that BIS has given out about $350 billion in Huawei waivers over the past five years. That’s surprising given Huawei’s presence on restriction lists. How do you both think about these trade-offs?
Nazak Nikakhtar: The Huawei situation is a perfect example of a policy issue that hasn’t been handled optimally in the last two administrations. We put Huawei on the entity list, but about a year and a half later, we switched the licensing criteria to mostly case-by-case, which statistically has a 99% plus approval rate. This approach is problematic from a policy standpoint and puts us in an awkward diplomatic position.
We’re asking countries like the Netherlands and Japan to restrict their exports of critical technologies to China, while we’re approving a high percentage of Huawei licenses.
This undermines our credibility when we ask other countries to impose restrictions.
Regarding the broader economic impact, when I was at the Commerce Department, we conducted an intellectual exercise to assess the economic impact of total decoupling from China, including financial flows, goods, services, and tech transfer. Assuming substitution, which we’re currently trying to achieve, the impact on US GDP was estimated at 3-5% in the short run, with enormous gains in the long run if we integrated our supply chains with allies rather than China.
I’m surprised to see reluctance in moving our supply chains, tech transfer, and capital flows away from China and integrating them with the rest of the world, given the potential for greater economic gains. This should be part of the ongoing conversation.
Peter Harrell: Regarding macroeconomic impacts, we’ve seen a lot of “sky is falling” rhetoric around traditional free trade economics since the Trump administration, with predictions that tariffs and other measures would devastate the global economy. However, we haven’t seen that happen. What we are seeing is that when there’s an orderly process allowing companies time to adapt and diversify away from China, we can address national security and economic security risks without causing major economic disruption.
I agree with Nazak that when the US is seen enacting tough regulations but then also creating numerous loopholes, it makes it harder to get allies on board with taking steps like export controls on semiconductor tools, which can be costly to their companies in the short term.
Regarding the Chinese market, especially for the tech industry, it’s true that China represents about 16-18% of the global economy. However, much of China’s dominance in tech product sales is due to its role as the world’s assembly floor. As supply chains diversify away from China, its share of the market for semiconductors and similar products will naturally decrease. Many of these sales, when cut off from China, will likely move to other markets rather than being lost entirely or captured by Chinese competitors.
Nazak Nikakhtar: Adding to Peter’s points, the argument that companies need China sales for revenue, especially in the semiconductor and equipment space, is no longer valid. Many countries are now implementing their own versions of the CHIPS Act, creating alternative markets for equipment makers. Just as we built China’s semiconductor manufacturing ecosystem, we can do the same in the United States and with our allies.
We need to critically rethink whether China is still the only market. If the answer is no, then we should encourage companies to stop selling to China. The more they sell to China, the less they’re selling here and to our allies. We’re trying to build these ecosystems now, and that should be our focus.
Jordan Schneider: I want to push back a little — the estimate of a 5% short-term hit to GDP growth if the US and China stopped trading immediately seems low, considering potential inflationary effects.
Moreover, it’s important to remember that a president’s top priority isn’t necessarily the US-China relationship. Foreign policy might occupy about 20% of their time, with only a fraction of that dedicated to Asia-Pacific issues.
It seems unrealistic to expect an entire national vision for a presidency to revolve around supply chain resilience or similar issues. Peter, you’ve been tweeting about Trump’s vision for tariffs and its potential second-order economic impacts. Can we discuss the tariff story and, more broadly, how far we can push the issues we care about without significantly impacting other domestic priorities?
Peter Harrell: I’m deeply skeptical of Trump’s proposed 10% global tariff. While we often discuss tariffs on China, this proposal would apply to imports from everywhere else, including everyday items like avocados from Mexico and Ozempic, which is primarily manufactured in Europe. This approach would likely increase costs for consumers without providing much strategic benefit.
Tariffs are an appropriate tool to protect our market from unfair Chinese competitive practices and to safeguard strategic industries. It’s important to focus not just on China as a territory, but also on Chinese goods and companies, as products can be diverted through other countries. However, we should primarily target our tariffs on China rather than on goods from our allies and partners.
A good example of effective tariff use is the electric vehicle (EV) and battery component tariffs. These tariffs, initiated under Trump and recently increased to 100% by Biden, have protected the U.S. market from being flooded with cheap Chinese EVs, as we’ve seen happen in Europe.
As China continues to subsidize its EV sector, driving costs down further, the Biden administration took steps to increase these tariffs to maintain protection for the U.S. market against unfair Chinese production practices.
Nazak Nikakhtar: The focus on supply chain resilience is crucial because it’s fundamental to preserving both the U.S. economy and military capabilities. Currently, our military relies heavily on critical supply chains in China, which forms the basis for these arguments.
Jordan, you mentioned doubts about the credibility of the report. While economic models may yield different results, the key points are twofold. First, logically, we would benefit from integrating our economies and supply chains with allies who adhere to fair trading rules. Without intellectual property theft and other unfair practices, our economies should grow faster. Second, the report does account for substitution. Remember, over 20 years ago, before China joined the WTO, we could still obtain everything we needed. The idea that gradually moving away from China will cause economic catastrophe is overstated.
Jordan Schneider: But Nazak, what about high-tech products like the Apple Vision Pro? I don’t think India will be producing something like that anytime soon.
Nazak Nikakhtar: [Laughs] My family members would agree with you.
Peter Harrell: Working with allies and partners to diversify away from China is crucial for several reasons. It strengthens allied relationships and provides access to commodities and technologies we may lack. Additionally, a larger market is necessary to compete effectively with China.
A recent example is the partnership between the US, Finland, and Canada to build polar icebreakers.
This collaboration creates a critical mass in market share, enabling the construction of a competitive, economically viable icebreaking ship industry. This partnership partly resulted from Russia sanctions, which forced Russian owners out of a Finnish shipbuilding yard, allowing Canadian investors to step in.
Jordan Schneider: That’s fascinating. While we often focus on major industries like semiconductors, these creative initiatives in niche markets where the government plays a larger role seem like an exciting way to address supply chain resilience.
Peter Harrell: Exactly. To build resilient, non-China-dependent supply chains, we need to consider both incentives and market viability, which requires scale and protection against subsidized Chinese products that raise national security concerns.
Jordan Schneider: I understand the supply chain argument, but there are trade-offs involved in pursuing an aggressive decoupling strategy. We shouldn’t completely disregard the gains that global consumers and firms have experienced from integrating China into the global economy.
Nazak Nikakhtar: It’s a fair point. When I mentioned the situation 20 years ago, I didn’t mean reverting all our technology to that time. The key is that we had resilient supply chains then, and technology was still progressing. Technology will continue to advance with or without China.
My conclusion that we need to disentangle our supply chains from China stems from the fundamental issue that the Chinese government controls its economy, creating a distorted, non-market system. Markets function better when market economies work together. Introducing a distortive element disrupts the equilibrium and flow of the global market.
If we accept this premise, it’s logical to remove these distortions to ensure a healthier economy. This doesn’t mean abandoning the global trading system, but rather looking to eliminate distortions and trading primarily with countries that are market actors.
Jordan Schneider: Peter, here’s a question from the audience about outbound investment screening. The notice of proposed rulemaking outlines two approaches for exceptions to passive investments in foreign funds investing in restricted tech in the PRC. Option one is to allow investments unless they’re active, while option two is to capture all investments over a million dollars. What’s your take?
Peter Harrell: I believe we should capture all investments over a million dollars. It’s important to address passive investments, but we need to differentiate between investments in publicly traded securities of Chinese firms and private passive investments. The outbound executive order correctly excludes investments in publicly traded securities of Chinese firms. The U.S. government already has a tool to prohibit Americans from investing in these securities: the CMIC sanctions list. The Biden administration should actively use this list for that purpose.
Regarding passive private investments, such as putting millions of dollars into a private AI firm in China, these should absolutely be captured by the outbound investment rule. There’s no other tool to capture this type of private investment, and we don’t want American dollars funding AI technology development in China.
Jordan Schneider: Additionally, a 2023 CSET report on US investment in Chinese AI presents a strong case about the soft support provided by these investments. The capital may be fungible, but there’s also the aspect of know-how and global connections that VCs bring alongside their money. This is particularly concerning for critical dual-use technologies. [Ed.: See the “Understanding the Intangibles section of this report].
Peter, since you mentioned you’re writing a book and reading some history, do you have any interesting documents or anecdotes you’ve come across?
Peter Harrell: I’ll share two historical examples.
First, in recent years, there’s been debate about balancing antitrust measures against large American tech companies with maintaining a competitive edge against China. A similar tension arose in the early Eisenhower administration, when the FTC prepared a report on American oil companies’ involvement in global oil cartels. The State Department tried to suppress the report, believing these companies championed U.S. interests globally.
The second example relates to supply chain resilience — specifically, the balance between substitution with new innovations vs investment in established technologies. During World War II, the U.S. was facing a rubber shortage due to Japan’s invasion of British Malaya, America’s primary source of rubber.
While Henry Ford attempted to build alternative supply chains in Brazil, the solution came from the FDR administration bringing together major American tire and rubber companies to develop commercially scalable synthetic rubber. This case is relevant to our current debates about critical minerals.
Creative Lawyering
Jordan Schneider: As we have two lawyers on the podcast today, I’d like to share an anecdote. I recently proposed a new government regulation idea to a civil servant, who asked me to write the regulation myself. When I asked about using government lawyers, they responded that lawyers only tell them what they can’t do. What’s your take on this dynamic?
Peter Harrell: Creative lawyering is crucial for effective policymaking. We need lawyers who can work within existing statutory frameworks to find solutions, whether it’s for CFIUS, IEEPA, or export controls. As a lawyer in policy roles, I’ve found it helpful to engage in legal arguments with internal counsel, challenging their interpretations when necessary.
While it’s important for lawyers to say “no” when something is genuinely illegal, the ideal balance is having someone who thinks creatively to find legal solutions and has the integrity to refuse when a proposal is truly unlawful. One advantage of working on China-related policy is that Congress has been willing to enact new laws addressing emerging threats, as seen with the recent TikTok legislation.
Nazak Nikakhtar: I agree with Peter’s points. The core issue is how government attorneys perceive their role. Many view themselves as advisors who highlight litigation risks rather than as partners in finding creative solutions. While there’s always litigation risk, it shouldn’t be a deterrent. Instead, we should weigh the likelihood of success.
It’s crucial to rethink the roles of everyone in the U.S. government, including policymakers, lawyers, and economists. Given the significance of the problems we face, it should be incumbent upon everyone to think creatively about solutions, as we’re not yet where we need to be in terms of addressing these challenges.
Jordan Schneider: Peter, we discussed bureaucratic barriers to competition the last time you were on ChinaTalk.
We’ve covered anxious lawyers, presidential direction, and feuding cabinet members. Would you like to assign percentages to these factors in terms of what’s hindering progress?
Peter Harrell: I’d rather not assign percentages. However, I don’t want to leave a negative impression. Looking back at my government service since 2009 and my earlier career covering foreign policy on Capitol Hill, I see a significant change in China policy. The implementation, compared to even 2009-2012 when I was at the State Department, has undergone a total transformation. While the process hasn’t been entirely smooth, we’re in a much better place now across two administrations. Despite occasional frustrations, I’m optimistic about the future. Regardless of the November election outcome, I believe we’ll see further steps to secure our supply chains, maintain our high-tech advantage over China, and build global diplomatic coalitions.
Nazak Nikakhtar: From my perspective, what’s been missing from the U.S. government is a team at the White House level with qualifications similar to Peter’s. We need to broaden the team that can articulate how to achieve our goals, slow down technological and military growth, and deter threats. This strategy should list all the tools in our arsenal and direct federal agencies to execute, rather than taking a reactive approach. A small team of visionaries who understand how these legal tools work could develop and implement a strategic vision. This level of thought and strategy in the White House could significantly improve our effectiveness.
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我希望你可以适当少一些焦虑，你考虑问题很周全了，有时候不需要规划好未来的每一步再出发。我希望你以后也会喜欢自己的工作，或者早日干上你喜欢的事情，厨子、司机、咖啡师。希望你一直这样勇敢，自由。希望你早日把小狗接来，希望你的ID卡早点变绿……现在你是一个real tough kid, who can handle her own shit, 偶尔也可以不那么tough啦。
Chien-ming Lin is a Taiwanese computer scientist. Previously, he spent five years studying and working in Beijing.
I’ve been waiting for the release of Black Myth: Wukong 黑神话：悟空 for four years. On the day the game was released, August 20, it set a new record with 2.2 million peak concurrent users on Steam, more than any other single-player game in history.
The CCP wants people to spend less time playing video games. State-affiliated media refers to video games as “spiritual opium.” The number of hours children are allowed to spend gaming is strictly regulated.
That rhetoric and policy direction may seem extreme — but the CCP is responding to a domestic gaming industry that’s often, frankly, exploitative.
Consider the video game Genshin Impact. Genshin is markedly Japanese in style, mimicking Nintendo’s classic Legend of Zelda with a “skin-changing” 換皮遊戲 format, designed to squeeze the player base for massive profits. It relies on built-in gambling mechanics — essentially like a capsule-toy gacha machine for mobile — and it’s very good at taking players’ money.
MiHoYo, the development company behind the game, wanted to obscure its Chinese origins. The name “Genshin” is a Japanese pronunciation of the Chinese characters yuánshén 原神, and “MiHoYo” also sounds quite Japanese. Perhaps MiHoYo wants to hide its Chineseness to appeal to the global market (only 30% of the game’s revenue comes from players in China). Or perhaps this was because MiHoYo felt it would be shameful to put a Chinese face on extractive microtransactions.
And when Genshin wasn’t busy exploiting its Chinese player base, MiHoYo was content to leave those players by the wayside and instead focus on attracting overseas players. In large part, that’s because MiHoYo knew Genshin was up against Tencent’s massively addictive Honor of Kings 王者荣耀 — a mobile rip-off of League of Legends which relies on the same gambling-for-characters model as Genshin. Honor of Kings is the most profitable mobile game of all time, raking in 10 billion RMB yearly; 95% of that comes from inside China.
In other words, Chinese game developers treated their player base like jiǔcài 韭菜, a crop of vegetables. But Black Myth: Wukong broke that mold.
Latent Demand for Chinese Culture
Daoists believe that god status is earned and achieved, not just reserved for divine beings. Follow the path (ie. dào 道), and you can become a god yourself.
That sounds like a great setting for a video game, right? Black Myth was not the first to take notice and capitalize. Two other games came first and defined the genre: The Romance of the Three Kingdoms 三國志 (1985, Japanese), and The Legend of Sword and Fairy 仙劍奇俠傳 (1995, Taiwanese).
These games are regarded as classics, beloved by Chinese players — but neither was made in mainland China. This dilemma is a familiar one for China’s cultural exports (how could DreamWorks produce a film like Kung Fu Panda before any Chinese company?), and the challenge inspired a generation of Chinese developers who dreamed of producing games that showcase Chinese culture globally, instead of waiting for foreign companies to tell those stories.
These young gamers grew up, passed the gāokǎo, and got the credentials necessary to design such games. But they despaired when their bosses at Tencent ordered them to bury their passion for coding such games and instead get Asia hooked on online gambling.
One disaffected developer was Mao Xingyun 毛星云. He wrote foundational Mandarin-language textbooks on game programming in Windows. Microsoft awarded him the Most Valuable Professional award in 2014, while Mao was still a graduate student.
He committed suicide in 2021 by jumping off the roof of the Tencent office building where he worked. After his death, this post from Mao’s Weibo account resurfaced:
To the Revival of Our Domestic Games:
I have a dream that one day in the future, everyone will be able to play high-quality games rooted in our own culture.
I have a dream that one day, “Journey to the West” will be released as an action game, allowing foreigners to experience the thrill of battle in Chinese culture through “Fighting Buddha.” It would surely be deeper and more profound than Western action masterpieces like “God of War” or “Devil May Cry.”
I have a dream that one day, “The Bund” will be released as a sandbox game, so we don’t have to play “GTA” to feel the American dream, or play “Sleeping Dogs” to experience a foreign company’s forced interpretation of our “Chinese culture.”
I have a dream that one day, many AAA titles won’t need to be localized into Chinese, because they will be our own games, with Chinese voice acting and culture.
I have a dream that one day in the future, domestic games will stand tall like other Chinese industries, taking the lead as they face the world, face the universe, with pride and confidence.
This is a dream we will achieve together.
I am waiting for the good news.
~ Mao Xingyun, June 2013, in Ukraine
Before Black Myth, China’s gamers often played pirated versions of American or Japanese games. But most players in the Chinese audience wouldn’t dare pirate Black Myth — they know how demand signals work, and they want to vote with their dollars to fund a grassroots shift across the whole of China’s game development industry.
That’s why this game activated such a wide base of support — players pay only once, up front, and are free to play as much as they want. Players know that it cost US$40 million to develop this game. They remember when the trailer was released four years ago, along with an employment offer for young game developers who didn’t care much for money.
This game shows that Chinese culture can be cool.
Of course, you do need a pretty fancy gaming PC or a PS5 to play. The fact that Black Myth became the world’s most popular video game overnight, though, shows that the gamers of China are willing to shell out big bucks to support this new era in gaming.
Journey to the West
Black Myth: Wukong is based on “Journey to the West” 西遊記, one of the great classical Chinese novels. In China and Taiwan, every student studies this novel in primary school.
The novel tells the story of the monk Xuanzang 玄奘, who traveled from China to India to collect Buddhist scriptures to bring back to China. Xuanzang was protected during the journey by Sun Wukong 孫悟空, the Monkey King, who became a god through Daoism, rebelled against heaven, and now must atone.
In Black Myth, you play as Sun Wukong, complete with shapeshifting abilities and other powers earned through the practice of Daoism.
The Monkey King has deep cultural significance in China. During China’s Cultural Revolution, much ancient Chinese culture was purposely destroyed and replaced with worship of communist ideology. (Perhaps that’s why China has struggled to produce cultural exports like Japan has with anime and Korea has with skincare and idol groups.)
But the Monkey King was spared during the Cultural Revolution, and Journey to the West remains a beloved classic. Here’s The Economist’s reflection after an adaptation of The Monkey King was released on Netflix:
Each Monkey King retelling has served as a mirror on its times, reflecting the anxieties of its creators. Some interpretations have concentrated on the need for discipline to quell the inner voice. Others have stressed the democratizing elements of a story about a lowly being who rises to great heights.
Flexible interpretation of the novel’s message has allowed the story to thrive in Communist China, even when other aspects of traditional culture were crushed. Mao Zedong admired Monkey King, who repeatedly challenged the hierarchies of Heaven, as a “wrecking ball who battles the forces of tradition,” says Julia Lovell, who translated the novel into English in 2021. A stage adaptation of the classic in 1955 praised Monkey’s “working-class wisdom” in defeating his oppressive rulers, the court of the mythical Jade Emperor. During the Cultural Revolution some of Mao’s Red Guards likened themselves to Monkey Kings, rebelling against the Party as Monkey did against the immortals.
The game’s graphics are directly imported from 3D scans of ancient Chinese architecture. The resulting visuals are stunning, which explains why the game uses up so much hard drive space. From Southern People Weekly 南方人物周刊:
In the game, players can see Yan-style 颜体 calligraphy of the Diamond Sutra 金刚经 carved into cliffs, Western Xia 西夏 dynasty’s stone tablets standing on northern plains, and weathered Buddha statues with broken arms…
Yang Qi 杨奇 and his team … scanned buildings such as Foguang Temple 佛光寺. Then, they scanned buildings and statues from the Wei 魏, Jin 晋, and Song 宋 dynasties, and then vessels and pottery from the Ming 明 and Qing 清 dynasties.
…
These artworks, shaped by generations over centuries, had been restored dozens of times and weathered by the passage of time, resulting in colors and textures that were nearly impossible to replicate.
Yang Qi told his colleagues in the 3D team that they must preserve every detail of the items they scanned, including the current color, damaged corners, weathered details, and even the grass stems embedded in the statue and small bits of exposed wire. “It’s very cool to look at it from the current perspective and observe the time at the same time,” said Yang Qi.
From this perspective, Black Myth: Wukong can be said to be a “Chinese tourism simulator” 中国旅游模拟器. The game’s sculptures of the Twenty-Eight Constellations come from scans of the Jade Emperor Temple in Jincheng, Shanxi 山西晋城玉皇庙. The setting of the Great King Huangmei 黄眉大王 — xiǎoxītiān 小西天 — is modeled after the Shuilu A Temple in Lantian, Shaanxi 陕西蓝田水月庵. The statues of Pilu Buddha are scanned from Mingshan Temple in Anyue County, Ziyang, Sichuan 四川资阳安岳县的茗山寺. The game also recreates aspects like the transformation sequences of hell, the Western Pure Land, and the protective deities’ niches from the Dazu Rock Carvings in Chongqing 大足石刻.
The most difficult boss of the game is Yang Jian 楊戩 (aka Erlang Shen 二郎神), who leads the army sent by heaven to punish Sun Wukong for his disobedience. Yang Jian is a major antagonist and drives the plot throughout the entire game, but he’s actually not the final boss — defeating him is so difficult that the developers made it optional. If you defeat the final boss without first confronting Yang Jian, the game ends with Sun Wukong being imprisoned in a rock instead of being reincarnated.
There are three phases to the fight with Yang Jian, and each phase comes with new attacks, new environmental hazards, and new combinations of attacks from previous phases. He has a resilience system for blocking the player’s attacks and defeating him requires expert use of in-game items, treasures, and spells.
For China’s independent game developers, however, the boss battle has only just begun. Rumors are already circulating that Tencent and MiHoYo are trying to poach the programmers behind Black Myth.
Tencent already tried to build this game when it released Asura/God of War 斗战神, an MMORPG that was initially so well received that players burned through content faster than Tencent could produce it. After the third chapter of the game, Tencent started cutting corners on production to reduce costs, losing most of its player base in the process. Tencent disbanded the God of War production team, and the developers they fired went on to found Game Science, the company behind Black Myth.
If we really are witnessing a shift in China’s gaming industry, it remains to be seen whether giants like Tencent will be able to re-enter the market they patronized and abandoned.
Jordan Notes on the Game
It’s good for world peace for China to succeed on the global stage in cultural exports. I would much rather have nationalist pride fed with Olympic sports, video games, and movie exports than Kinmen and Spratly’s. There’s all this angst in Chinese political discourse about not being looked upon as a first-rate nation by the rest of the world. Let’s all hope that this chip on politicians’ and netizens’ shoulders can be ameliorated by video game sales and not ADIZ violations.
When I published this contemporary Chinese music roundup by Jake Newby of Concrete Avalanche, which featured everything from psychedelic rock and Beijing kawaii core to Uyghur folk and Tibetan chants, someone in the DC policy universe reached out to me and said “This deradicalized me a bit — I didn’t know people made music in China like this!” I do hope that this game can do the same and remind people that there’s more to China than the Party.
One interesting dynamic that an article in The Initium highlighted was the self-policing going on in the online discourse of fans encouraging each other not to engage at all with the critiques around Game Science’s apparent misogyny in its leadership’s past posts and recruiting marketing to preserve the good energy around the release. It’s also curious that just as the game was being praised in state media for its achievement, someone dug up a 2013 Weibo post of Black Myth lead artist Yang Qi flipping off Mao’s portrait at Tiananmen Square that has some real Ai Weiwei energy. We live in different times…
On the game itself, I find it interesting how little handholding there is in the game’s story — it gives you very little in-game context on who its characters and monsters are, expecting that the audience will broadly already get the references. Setting aside its positive reception in the West (82 on Metacritic), this is first and foremost a game made for a Chinese audience. 90% of the Steam player base, after all, is based in the PRC.
It is also hard — I’ve put an hour into this snake boss — and I don’t think I’ll go much further until there are mods to make it easier. It’s not like Elden Ring where you can explore your way around a boss or use clever game mechanics to compensate for being bad. That said, the visuals are glorious, clearly made with a ton of love and care. It’s also been my first experience of cloud gaming, with NVIDIA’s GeForce Now working surprisingly smoothly even on my non-fiber connection. This game will reset the Chinese videogame equilibrium, giving publishers confidence to invest in not just exploitative mobile games but creative products, and I could not be more excited to see what comes next.
Let’s close with a line from a Steam review: “130GB on my hard drive really isn’t that big, because in those gigs is not just a game, but countless Chinese dreams of a AAA game.” “接近130GB的硬盘空间占用并不算大，因为它装载的不仅仅是一个游戏，而是无数中国人属于自己的3A梦.”
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