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Leon Liao's avatar

Unfortunately, I think the article’s reading of China’s new supply-chain regulation could be somewhat misleading for multinational business leaders considering investment in China.

The first problem is that the piece frames the regulation as if it were simply an “export control law.” That is not quite accurate. Its formal title is the Regulations of the State Council on Industrial Chain and Supply Chain Security, and its scope is much broader than export control in the narrow sense. It is better understood as an umbrella framework that bundles together industrial security, information security, risk monitoring, emergency response, and countermeasure capacity. In other words, this is not just about adding one more layer of restriction at the export end. It is about formally elevating “industrial chain and supply chain security” into a governance system that can mobilize multiple agencies, monitor risks, issue warnings, conduct investigations, and impose countermeasures. 

The second problem is that the article presents the regulation too much as if it were designed to indiscriminately intimidate all foreign firms. But the opening part of the regulation repeatedly stresses “coordinating development and security,” “advancing high-standard opening up,” and “promoting the stable and smooth operation of global industrial and supply chains.” It also explicitly says that China will “encourage and support enterprises” to diversify supply channels, carry out industrial and supply-chain cooperation, and participate in market competition on an equal footing. That suggests this is not a simple closure document. It reflects a dual objective: to remain open and keep supply chains functioning, while also institutionalizing stronger tools around security in key sectors, data security, and external countermeasures. Put differently, the message is: business is still welcome, but under conditions of security tension and geopolitical friction, the state intends to retain stronger intervention rights. 

The third problem, and the most important one, is that the article interprets this mainly as China moving from reciprocal retaliation to proactive offensive action. But if you look at the text itself, the core logic of the regulation does not emerge independently of China-US friction. It is explicitly built on the existing legal architecture around national security and countermeasures. Article 14 directly addresses cases in which foreign states, regions, or international organizations impose discriminatory prohibitions, restrictions, or similar measures against China in the industrial and supply-chain sphere. Article 15 addresses cases in which foreign organizations or individuals interrupt normal transactions or adopt discriminatory measures that cause, or threaten to cause, substantial harm to China’s industrial and supply-chain security. In other words, this framework remains deeply embedded in the context of resisting external containment, extraterritorial coercion, and the weaponization of supply chains. It is not some entirely new offensive industrial weapon appearing out of nowhere. What is really happening is that China is taking the more fragmented countermeasure thinking of the past few years and turning it into a more administrative, procedural, and normalized system. 

The fourth problem is that the article makes it sound as though a foreign company conducting its own supply-chain audit could inherently be illegal. But Article 13 does not ban all information-gathering related to industrial and supply chains. What it prohibits is conducting such investigations or information-collection activities in violation of Chinese laws, administrative regulations, departmental rules, or relevant state provisions. That distinction matters. It means the risk is not “auditing itself.” The real issue is whether activities such as auditing, due diligence, mapping, data transmission, supplier screening, or the organization of information in sensitive sectors cross the boundaries set by China’s existing rules on national security, data, surveying and mapping, counter-espionage, or personal information. So the real change is not that “all due diligence is now illegal.” The real change is that companies can no longer assume their globally standardized compliance, audit, and data-transfer procedures will automatically be treated as neutral in China. 

Taken together, this regulation does not in itself mean China is about to arbitrarily launch a large-scale crackdown on foreign firms. The bigger shift is that it signals to all multinationals that operating in China can no longer rest on a clean separation between “commercial behavior” and “geopolitical behavior.” In the past, many firms believed they were simply doing compliance work, audits, or supply-chain adjustments. Now those same actions may increasingly be reinterpreted through the lens of national security and industrial security.

Leon Liao's avatar

It is right to identify why Silicon Valley is becoming increasingly drawn to Chinese AI: China is turning low-cost token generation into a structural advantage. Some Chinese models charge only around $2 to $3 per million output tokens, versus roughly $15 for Anthropic’s Claude Sonnet, a gap of nearly 6x. That cost differential is already pushing some U.S. companies, including Airbnb, to adopt Chinese large models.

That said, this post’s understanding of this advantage is still incomplete. It argues that one reason is lower electricity prices in China, when in fact U.S. industrial electricity prices are generally lower than China’s. Its second point is more convincing: China’s embrace of the MoE path did emerge partly under conditions of compute constraint, and those constraints do force companies to focus more intensely on inference efficiency, model compression, and unit-cost optimization. But the problem is that MoE is not a uniquely Chinese method, nor is it a technological path that naturally implies durable Chinese leadership. It is better understood as a tool that, at least for this stage, amplifies China’s engineering strengths.

I would add two points.

First, this should not be read too optimistically for China AI. What is truly worth paying attention to is not simply that Chinese models are cheaper. It is that China may be developing a broader system-level capability to keep driving inference costs down while diffusing AI rapidly into real industrial and commercial use cases. But that is still very far from proving that the global center of AI power has already shifted. In reality, AI competition needs to be broken down into at least four layers. The first is frontier model capability: who is closest to the technological frontier. The second is inference cost: who can produce tokens more cheaply. The third is systems integration: cloud infrastructure, networking, memory, packaging, power, and data-center orchestration. The fourth is the application ecosystem: whether these capabilities can actually be absorbed by enterprises and consumers at scale. Frontier models, the compute foundation, cloud platforms, enterprise gateways, and global capital markets still remain, to a very large extent, in American hands today. I discussed this in an earlier post as well.(https://leonliao.substack.com/p/low-cost-open-models-are-squeezing?r=731anr&utm_medium=ios)

Second, cheap tokens do not automatically mean value capture will accrue to China. In the AI value chain, the party that produces tokens, the party that consumes them, the party that defines application-layer standards, and the party that controls customer relationships are not necessarily the same. Even if Chinese models provide cheaper inference in certain scenarios, the entities that ultimately capture the profit pool may still be American platform companies, cloud providers, enterprise software firms, or application-layer players that control distribution. This is no different from manufacturing: the lowest-cost producer does not necessarily capture the highest profits. What ultimately determines profit distribution is system control, branding, access points, standards, and customer stickiness. I have discussed that in another post as well.(https://leonliao.substack.com/p/chinas-token-exports-are-explodingwhat?r=731anr&utm_medium=ios)

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