The following is excerpted from our full report, which contains interactive charts, a breakdown of our methodology and evidence, and a comparison to other estimates.
Key takeaways
Substantial quantities of AI chips have been sent to China in violation of US export controls. Evidence of diverted or missing chips, drawn from indictments and investigative reporting, points to nearly 300,000 Nvidia H100-equivalents by the end of 2025. This would equal roughly a quarter of the compute China acquired through legal channels or domestic production. Because much smuggling goes undetected, the true total is likely higher.
We estimate, with 90% confidence, that between 290,000 and 1.6 million H100-equivalents of compute were smuggled through the end of 2025. Our median estimate of 660,000 represents roughly 3% of the global compute stockpile, comparable to what xAI, a leading US AI lab, had at the time. The upper bound of our estimate would mean that, by the end of 2025, the majority of China’s AI compute had been smuggled.
We are uncertain about many variables, notably the magnitude of undetected smuggling and the proportion of chips allegedly diverted or missing that ultimately reached China.
Overview
Over the past several years, the United States has applied multiple rounds of compute-related export controls to China. The earliest rounds of export controls applied to semiconductor manufacturing equipment or to specific entities (e.g., Huawei’s addition to the BIS entity list in 2019). In October 2022, the Commerce Department instituted export controls on all advanced chips with certain characteristics. Commerce tightened these export controls and expanded their scope in October 2023, increasing the incentives for smuggling chips to China. A late 2023 Center for New American Security (CNAS) analysis suggested that the volume of smuggled chips at the time was relatively low, but expected that there would be larger-scale smuggling efforts in the future.
This prediction appears to have been borne out. Investigative reporting by the New York Times, Wall Street Journal, and The Information in 2024 found widespread evidence of banned chips being smuggled into China. In April 2025, Commerce imposed an additional licensing requirement on H20 chips, a type of chip popular in China that Nvidia had developed to comply with prior export controls.1 This further restricted exports and incentivized smuggling. The Financial Times reported that over $1 billion in AI chips were smuggled between April and July.2
Evidence of large-scale diversion by cloud companies has also accumulated. The DOJ indicted several Supermicro employees and arrested a company executive. The employees were accused of diverting $2.5 billion in Nvidia chips to a pass-through entity, which was redirecting those servers to China. Bloomberg investigative reporting insinuates that Megaspeed, a Singaporean cloud provider, has tens of thousands of fewer chips in its Malaysian data centers than it imported from Nvidia, and its CEO is under scrutiny due to close ties to China.
We estimate the total compute smuggled to China using Monte Carlo simulations3 based on evidence from indictments and investigative reporting. We classify this evidence into two types. Diversion evidence traces how chips leave legitimate supply chains and reach smugglers. Resale evidence focuses on the marketplace for smuggled chips within China: the number of vendors or brokers and volumes they transact. Some sources cover both diversion and resale of the same set of chips.
Because every successfully smuggled chip must be both diverted and resold4, we can build two parallel estimates of the same underlying quantity that should, in theory, approximately agree. While our resulting distributions for diversion and resale aren’t identical, they do substantially overlap.
The diversion estimate is created by building a database of allegations from 2024 and 2025, and then adjusting for false or overstated allegations, and for cases missed by reporting and enforcement5. The database does not include cases where diversion was attempted but known to have failed. The resale estimate approximates total volume in the market for smuggled compute by aggregating investigative reporting on vendor counts and the scale of individual transactions. The resale estimate draws on portions of a 2024 CNAS estimate of smuggled compute by Grunewald and Fist.
Cumulative allegations of diverted or missing chips total almost 300,000 H100e6 by the end of 2025 — a quarter of the compute that China is estimated to have legally imported or domestically produced. This figure is neither a ceiling nor a floor on actual smuggling. This figure may overstate actual smuggling for two primary reasons: the allegations are largely not yet proven in a court of law, and some of the chips redirected to China may not have arrived there. Conversely, the 300,000 estimate captures only publicly alleged cases — some, probably most, smuggling goes undetected by journalists and authorities. Thus, we believe it is almost certain that the true total quantity of compute smuggled into China is higher than 300,000. More details and a cumulative summary of reported and alleged smuggling are here.
Our model estimates 660,000 (90% CI: 290,000–1.6 million) H100e of cumulative compute smuggled through the end of 2025. This is somewhat higher than other estimates, including those by CNAS and ChinaTalk, though the median is well within their confidence intervals and vice versa. A comparison against these other estimates, including a discussion of the differences, is available here. Further details on the model and our estimates are here. Our estimates cover quantities of chips and servers physically moved into China. They do not cover cloud compute located outside of China but used by Chinese customers, an arrangement that, subject to end-use restrictions and sanctions-list screening, is generally permitted under current US export controls. These estimates can be viewed in a global context by checking out Epoch’s AI Chip Ownership Hub.
Read the full report for interactive charts, a breakdown of our methodology and evidence, and a comparison to other estimates.
China had imported almost 18 billion dollars' worth of H2Os, around 220,000 H100e units, between their 2024 introduction and their ban.
While the H20 restrictions were lifted by the US in July 2025, China subsequently restricted H20 imports. While the initial lifting of the restrictions appeared to reduce demand for gray market chips, it is unclear whether gray market sales rebounded when H20 sales did not resume.
Simulations that involve repeatedly drawing random values for each uncertain input to build up the distribution of possible outcomes.
In some cases, the end user may be directly arranging for the diversion of the chips, typically through a shell company or other pass-through entity. We then consider the transfer of the chips from the pass-through entity to the end user to be the resale step. It is possible that some chips may be smuggled in more directly by the end-user, but we anticipate that this is small in proportion to total flows.
We assume reporting is accurate with a median of 80%, 90% CI (61-94%) and that the detection rate is between 10-60% (90% CI), with a median of 24.5%. In addition to an overall reporting discount, for each case, there is case-specific uncertainty about whether purportedly missing or attempted diverted chips made it to China.
Compute capacity in the equivalent number of Nvidia H100s, based on dense 8-bit operations per second.
