Economic Warfare & Trade Policy Tech & export controls

An SK hynix export license fight in Washington is now tied to one of the largest chip investments floated for New York. Reuters reported Tuesday, Nov. 3, 2026, that the U.S. Commerce Department has not approved licenses for American chipmaking tools SK hynix wants to expand its memory plant in Dalian, China, complicating a reported plan by its U.S. unit, Solidigm, to build NAND flash plants in Marcy, N.Y. SK hynix said Wednesday its current license remains valid.
Key figures: About $45 billion reported first phase in Marcy, N.Y. · Up to about $100 billion over time · Nearly 10 Solidigm meetings with Commerce since late August · 2027 Dalian maintenance license still under negotiation
What Reuters reported about the New York plan
According to Reuters, which cited people familiar with the matter, Solidigm plans to invest about $45 billion to build two NAND plants in Marcy, a town near Utica, and the total could reach about $100 billion over time. NAND is the memory that keeps data when the power is off, and it is used for storage in data centers. The company has argued that more production in Dalian would generate the revenue needed to fund the U.S. build-out, Reuters said.
The reported plan has no public start or end date, and neither company has confirmed the figures. Solidigm repeated a statement it issued the previous week: it “is currently exploring options for building a NAND memory fab at potential locations around the world,” and “no decision regarding any specific course of action has been made.”
Reuters said Solidigm executives have met nearly 10 times with Commerce officials since late August. In a meeting last week, according to one person, Commerce Under Secretary Jeffrey Kessler held to his position that the U.S. would not allow more American tools to upgrade or expand capacity in China. The department has not formally denied a license to send equipment to fill empty clean-room space in Dalian, Reuters reported, and the two sides are separately negotiating a 2027 license for equipment to keep the plant running.
SK hynix’s response
On Wednesday, an SK hynix official told Seoul-based Aju Press that the company is still shipping U.S.-made equipment into Dalian under an existing license. “We currently have a valid license and are bringing in equipment with approval from the U.S. government,” the official said, adding that “negotiations for next year’s license are underway as part of the usual process.”
On the U.S. plant, the official said: “We recognize the need to build a semiconductor fabrication facility in the United States and are reviewing the possibility, but nothing specific has been decided.” As Aju Press noted, that answer does not address whether separate requests to expand capacity have been held up.
By the numbers

- Versus Indiana: The reported $45 billion first phase would be about 11.6 times the $3.87 billion SK hynix pledged in April 2024 for its HBM packaging plant in West Lafayette, Ind. The $100 billion figure would be nearly 26 times as large (TBR calculation).
- Versus Dalian’s price tag: SK hynix bought Intel’s NAND business, including the Dalian fab, in a two-stage deal worth about $9 billion that closed in March 2025. The reported New York first phase is five times that (TBR calculation).
- Paperwork at stake: Before switching to yearly approvals, Washington estimated that ending the old waivers for the Korean companies’ China plants could mean up to 1,000 individual license applications a year, Yonhap reported.
The Indiana project has since grown to more than $4 billion, and it is running later than first planned. SK hynix originally targeted mass production in the second half of 2028; Reuters reported in August that output there is now set to start in 2029. SK hynix posted record results last month on AI memory demand, as The Boston Report covered in SK hynix’s third-quarter earnings, and memory chips helped drive South Korea’s October export surge.
How the license rules changed
Until last year, SK hynix’s Wuxi and Dalian plants and Samsung’s Xi’an plant held “validated end user” status, which let them receive U.S. tools without separate licenses. The Commerce Department’s Bureau of Industry and Security announced in August 2025 that it would revoke that status, effective Dec. 31, 2025, according to the Federal Register and Yonhap. In late December, Washington moved to yearly approvals based on annual equipment plans, and both companies received approvals for 2026, Yonhap reported, citing industry sources. Reuters reported that U.S. officials have kept limits on shipments that would expand or upgrade production capacity in China.
The case shows the tension inside the Trump administration between drawing chip factories to the U.S. and enforcing export controls on China. “Ultimately, none of this is going to go forward without a green light from the White House,” Leland Miller, a member of the U.S.-China Economic and Security Review Commission, told Reuters. The White House and Commerce did not immediately respond to Reuters’ requests for comment. Allies are tightening their own rules too, including Taiwan’s proposed chip export bill.
What to watch
The next markers are the 2027 maintenance license for Dalian, any formal Commerce ruling on the expansion request, and whether Solidigm names a site. A confirmed site and dollar figure from Solidigm would be the first official sign that the New York plan is moving forward.
Sources
- Reuters via Investing.com: SK Hynix’s New York chip plans hit snag over US restrictions on China, sources say (Nov. 3, 2026)
- Aju Press: SK hynix says US chip equipment license remains valid (Nov. 4, 2026)
- Yonhap: U.S. eases chip equipment export restriction for Samsung, SK hynix plants in China (Dec. 30, 2025)
- Federal Register: Revocation of Validated End-User Authorizations in the People’s Republic of China (Sept. 2, 2025)
- SK hynix Newsroom: SK hynix signs investment agreement of advanced chip packaging with Indiana (April 3, 2024)
- Baker McKenzie: Advises Intel in $9 billion divestiture (April 2025)
- Reuters: SK Hynix to start AI chip output in Indiana in 2029, sees memory shortage through 2030 (Aug. 27, 2026)
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