Reps. Moolenaar and Whitesides want the Commerce Department to bar US firms from buying DRAM and NAND from Chinese memory makers CXMT and YMTC — the same suppliers Apple, Dell, and HP are reportedly qualifying.
Two US lawmakers are asking the Commerce Department to flip a half-built memory-chip policy: instead of restricting what American companies can sell to Chinese memory makers, the Trump administration should restrict what American companies can buy from them. The target is CXMT, China's main DRAM producer, and YMTC, its leading NAND maker, according to a letter from Reps. John Moolenaar (R-MI) and George Whitesides (D-CA) to Commerce Secretary Howard Lutnick, made public Thursday.
The ask lands in a tight market. Apple, Dell, and HP have reportedly begun qualifying memory from CXMT and YMTC, The Register reported, and the Financial Times reported Apple asked the Trump administration for clearance before engaging either company. The Register projects memory prices will stay elevated through at least 2028 because new wafer fabs take four or more years to reach volume production. That backdrop turns the procurement race into a near-term policy problem: alternative Western supply is not arriving fast enough to absorb the demand Apple, Dell, and HP would otherwise fill from China.
The shift the letter proposes is a procurement-side ban, not an export-side one. Today's regime already covers both firms. CXMT sits on the Defense Department's Section 1260H list of Chinese military companies, and YMTC sits on the Commerce Bureau of Industry and Security's Entity List. Those lists block American technology from flowing to them. They do not block American buyers from flowing dollars to them. The letter asks the administration to issue an executive order or agency directive closing that gap: barring US persons and US-incorporated entities from procuring memory components from YMTC, CXMT, or any entity on either list. If granted, the curb would land in the same quarter those OEMs are running qualification trials.
Moolenaar and Whitesides argue the curb is industrial-base policy, not trade retaliation. Chinese state subsidies, they write, could let CXMT and YMTC undercut Micron, SK Hynix, and Samsung on price, eroding the Western memory manufacturing base and indirectly subsidizing the People's Liberation Army. The letter's stated goal is to ensure Chinese memory makers "will never catch up to their Western counterparts." That language positions the curb as defense industrial policy, not trade retaliation.
The industrial-base goal may not survive the proposed instrument. A US-only procurement curb does little if CXMT and YMTC can scale on Chinese cloud and consumer demand alone, or route product through third-country incorporation. The letter does not address how the administration would police Chinese-owned memory shipped under a non-Chinese label, or how allied buyers in Europe and Asia would be brought into the same regime. What would make the curb stick is a parallel commitment from the EU, Japan, and South Korea to apply the same procurement rules to CXMT and YMTC memory. None of those allies have signaled that yet.
The next moves to watch: whether Commerce issues a formal procurement directive or relies on informal guidance to Apple, Dell, and HP; whether SK Hynix and Samsung, which already operate China-based fabs, get a carve-out; whether allied capitals join the curb; and whether the 2028 supply backdrop holds, because if memory prices fall faster than projected, the political case for the curb gets weaker before the policy machinery is in place.