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Outbyte Driver Updater FREEScan for outdated or missing drivers - takes under a minuteDriver Scan →Outbyte PC Repair FREERepair Windows errors before they cause bigger problemsFix Now →Yes—Chinese end users have continued to obtain export-controlled Nvidia GPUs, but that does not mean Nvidia is routinely selling them directly into China. Recent investigations identify university procurement and alleged diversion routes, while a U.S. smuggling case concerns H100 and H200 chips. Legal sales, licensed access and unlawful exports are different things, and the public evidence does not establish how many restricted GPUs are now operating in China.
What “still buying” means in this report
“Buying” can describe several different forms of access: a Chinese institution purchasing physical GPUs through a procurement chain, a buyer obtaining chips diverted through another country, or an organization using computing capacity remotely. The available evidence documents physical procurement and alleged export circumvention; it does not establish the scale of access through cloud services. Nor does access to Nvidia computing necessarily mean the end user owns the GPUs.
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“Sanctions” is also imprecise here. The measures at issue are primarily U.S. export controls and licensing requirements, alongside Chinese government restrictions on some purchases or imports. Whether a specific transaction was permitted depends on the chip’s capabilities, the date, the license, the parties and the destination—not just the model name.
How restricted chips have reached Chinese users
University and research-institution procurement
C4ADS reported that from July 2025 through January 2026, Chinese universities and research institutes in its defined procurement sample obtained at least 56 restricted Nvidia chips worth US$1.7 million. The report describes contracts that bundled chips with other purchases and used companies without the relevant credentials; it also says many of the institutions have government or defense-industrial links. These findings describe the sample C4ADS examined, not the total number of chips entering China. Read C4ADS’s September 9, 2026 analysis, Covert Compute: How Advanced AI Chips Reach China.
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Southeast Asian transshipment and corporate structures
C4ADS also describes alleged routes through Southeast Asia and corporate ownership structures involving an importer under U.S. scrutiny. Those findings point to ways supply chains can obscure a chip’s ultimate destination or buyer. They do not establish that every shipment through Southeast Asia, every intermediary, or every company in a complex ownership chain is unlawful.
A separate U.S. smuggling case
The U.S. Department of Justice says court documents in a case covering October 2024 through May 2025 describe at least $160 million in export-controlled H100 and H200 GPUs exported or attempted to be exported by defendants and others. The alleged methods include falsified shipping paperwork, concealed destinations, straw purchasers, intermediaries and relabeling. DOJ reports guilty pleas by one defendant and a company; other named people were charged or arrested, so allegations against them should not be treated as convictions. This is a case-specific figure, not a national estimate. See the DOJ case announcement and its account of the legal proceedings.
What U.S. and Chinese rules have meant for Nvidia sales
The rules and government positions have shifted over time. The following chronology helps explain why a chip’s model alone cannot establish whether a sale was legal or available:
| Date | What changed or was reported | What it does—and does not—show |
|---|---|---|
| October 2023 | Nvidia said U.S. licensing requirements covered products above specified performance thresholds, naming A100, A800, H100, H800, L4, L40, L40S, RTX 4090, GB200 NVL72 and B200 among examples. | The controls were based on product performance thresholds; the filing does not make every Nvidia GPU subject to the same restriction. Nvidia’s FY2027 second-quarter Form 10-Q discusses the requirements and their effects. |
| April 2025 | The U.S. government informed Nvidia that H20 exports to China, Hong Kong, Macau and certain other destinations or entities required a license. Nvidia recorded a $4.5 billion charge in fiscal 2026’s first quarter related to H20 excess inventory and purchase obligations. | The charge reflects inventory and purchase obligations associated with the licensing change; it is not a measure of chips smuggled into China. Nvidia’s filing reports the license requirement and charge. |
| July–August 2025 | China’s Ministry of Commerce said the U.S. had recently indicated it would approve H20 sales, while urging removal of U.S. restrictions. On July 31, China’s Cyberspace Administration said it had summoned Nvidia to explain alleged H20 security risks and provide supporting materials. Nvidia later said U.S. licenses would have allowed certain H20 shipments to certain Chinese customers, but PRC restrictions prevented sales of its H20 inventory. | The ministry’s statement is the PRC government’s characterization of U.S. policy; the CAC notice records an allegation and regulatory action, not proof of a vulnerability. Nvidia said its GPUs do not include the alleged built-in vulnerabilities. China’s Ministry of Commerce statement, CAC notice and Nvidia filing. |
| January 13, 2026 | The U.S. Bureau of Industry and Security announced case-by-case review of license applications for H200, AMD MI325X and similar chips, subject to conditions. | Review is not automatic approval. Applicants must protect capacity available to U.S. customers, maintain purchaser export-compliance procedures including screening, and allow independent U.S. third-party testing of performance and security. BIS’s announcement explains the conditions. |
| February 2026 onward | Nvidia said U.S. licenses allowed small H200 shipments to specific Chinese customers, but PRC restrictions prevented sales of all licensed products. The company said it made a fraction of the allowed shipments; in its most recent quarter, those shipments represented less than 1% of Data Center revenue. | The revenue share refers to H200 shipments under the licensing program in the quarter described in Nvidia’s FY2027 second-quarter filing—not to all Nvidia sales, all China revenue, or China’s total GPU supply. The filing also says the licensed H200s required U.S. inspection and faced a 25% tariff on import into the United States. Nvidia’s filing gives the company’s account. |
These are separate regulatory gates: a U.S. export license does not by itself ensure the Chinese government will permit a purchase or import. Conversely, the existence of U.S. controls does not prove that every chip reaching China was exported unlawfully.
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How much Nvidia hardware is in China?
The public figures above cannot be added together to produce a reliable national inventory. C4ADS’s 56-chip figure concerns a defined university and research-institution procurement sample over July 2025 to January 2026; DOJ’s at-least-$160-million figure concerns one enforcement case and includes chips allegedly exported or targeted for export over a different period. Their scopes and units differ.
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No comprehensive public inventory establishes how many restricted Nvidia GPUs currently operate in China. The evidence demonstrates continued access in particular settings and alleged diversion in a specific case; it does not reveal the total stock, the share that is still in operation, or how much compute is accessed remotely instead of owned.
What the restrictions mean for Nvidia’s China business
Nvidia’s disclosures show that the licensing regime and restrictions on Chinese purchases have materially constrained its ability to sell data-center products in China. In its FY2027 second-quarter filing, the company said it was effectively foreclosed from competing in China’s data-center compute market. It also said that even a competitive product with wide distribution required approval from both governments under the conditions it described.
That is consistent with the gap between licenses and completed sales: U.S. authorization can permit a shipment in principle, but Chinese restrictions can still block the sale. For investors, the figures in Nvidia’s filing describe company-specific charges and limited licensed shipments; they are not a measure of the value or volume of the gray market.
China’s domestic chipmakers are another part of the market picture. The Associated Press reported on June 29, 2026 that Nvidia had not sold H200s in China and quoted the company saying it had not generated revenue from them and was uncertain whether imports would be permitted. AP also reported analyst estimates from Bernstein: Nvidia had about 40% of China’s AI chip market in 2025, with its share forecast at around 8% for 2026 and Huawei’s at about 50%. These are attributed estimates and a forecast, not audited market statistics. The same report describes Huawei’s position as growing. Read AP’s market report.
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