The U.S. government has decided to allow foreign companies to participate in its ‘export of U.S.-made AI’ initiative, which it is pursuing to secure the lead in the artificial intelligence (AI) competition with China. Participation by South Korean companies such as Samsung Electronics and SK hynix, which possess memory manufacturing capabilities including high-bandwidth memory (HBM), a core element of AI hardware, is expected to gain momentum.

According to the U.S. Federal Register on the 16th, the Department of Commerce stated that foreign companies may apply to participate in the ‘full-stack U.S.-made AI export program’ as members of a consortium if they meet the ‘national security requirements’. In particular, regarding AI hardware such as semiconductors and servers, foreign companies must meet a requirement that ‘U.S. content’ (calculated including costs related to manufacturing in the United States) be 51% or more of the total value. If they have procured products or services from companies established in, or with major operations in, countries of concern such as China, they must disclose the relevant information.

However, if a foreign company “provides the highest-value products and services in AI hardware and AI models/systems and is judged to contribute to advancing U.S. national interests”, then, as an exception, the Department of Commerce said it may, after consultations with relevant departments such as State, Defense, and Energy, designate them for the export program on a case-by-case basis and designate the foreign company as a “national champion enterprise” (NCE).

The Donald Trump administration has encouraged the export of full-stack, U.S.-made AI to solidify U.S. dominance in AI and reduce reliance on the AI technologies of adversary nations.

As a result, South Korean semiconductor companies can now participate in the consortium for U.S.-made AI export packages. Previously, in December last year, Samsung Electronics and SK hynix submitted to the Department of Commerce a written opinion stating that participation by companies from allied countries would help secure the competitiveness of the U.S. AI stack and national security objectives, and that participation by foreign companies should be permitted.

The Department of Commerce made clear that, in the process of designating AI export packages, it would check the rise of China in AI and prioritize U.S. interests. Consortium participants must state whether they comply with U.S. national security related measures, such as the export control regime, outbound investment regulations, and end-user control policies. Also for data and security, AI use, and open-source AI models where China holds an advantage, companies that have business relationships with countries of concern such as China are effectively barred from joining the consortium.

AI full stack is defined as five layers: △ AI-related hardware and infrastructure such as semiconductors, servers, accelerators, data center storage, and cloud services △ data pipelines and labeling systems △ AI models and systems △ AI-related security and cybersecurity measures △ software and sectoral AI use in areas such as education, healthcare, and defense. The Department of Commerce said it will accept pre-set consortium proposals until June 30.

It is assessed that the U.S. opened the door to foreign companies because participation by allied firms with full-stack AI capabilities, including hardware, is key to realizing the AI export plan. South Korea has unrivaled manufacturing capabilities in memory, including HBM that is essential for AI accelerators from U.S. companies such as Nvidia and AMD.

An industry official said, “For the United States, cooperation with South Korea is essential to export full-stack AI, and this will be an opportunity for South Korean semiconductor companies, including expanded exports.” Cooperation in advanced technology between South Korea and the United States is also expected to expand further. However, because compliance with U.S. export controls on China is required, there is a view that this could weigh on the businesses of South Korean companies in China.