On December 13, SEMI submitted its response to a Request for Information (RFI) from the U.S. Department of Commerce (the Department) regarding the newly launched American Artificial Intelligence (AI) Exports Program. The intent of this program is to position U.S. firms as global leaders in AI by connecting them with international buyers, leveraging the Department's export promotion tools and supporting industry-led consortia through targeted government backing. By issuing this RFI, the Department intends to solicit input on the development of industry-led consortia capable of delivering full-stack American AI export packages under the American AI Exports Program.
Working with member companies, the SEMI Public Policy and Advocacy (PP&A) team developed a response highlighting the importance of the semiconductor supply chain to the AI ecosystem, and offering various recommendations for consortium formation, federal support, strategic objectives, and proposal evaluation. The response was informed by direct discussions between SEMI PP&A and Department officials implementing the program.
Some of the key aspects of SEMI's response include the following:
- Broader AI Tech Stack Definition: The Department should recognize semiconductor manufacturing technologies, mature node semiconductors, and energy/environmental control systems as foundational elements of the AI technology stack.
- Evaluation Framework: Evaluation criteria for consortium proposals should align with CHIPS for America requirements and guardrails, focusing on national security, economic competitiveness, and commercial viability, as well as infrastructure needs.
- Consortia Governance: Consortia should be industry-led and feature: honest brokers capable of coordinating commercial actors while advancing national interest objectives; modularity to ensure that the various technology layers function as distinct yet interoperable units; and clear frameworks for intellectual property protections and regulatory compliance.
- Foreign Participation: Vetted foreign entities should be allowed to participate in the program in order to reflect the global nature of the AI ecosystem and to strengthen allied and partner nation supply chain resilience.
- Federal Support Mechanisms: The Department should leverage the unique capabilities of the National Institute for Standards and Technology, Center for AI Standards and Innovation, Bureau of Industry and Security, Export-Import Bank, Development Finance Corporation, and others, including expedited licensing, financing tools, tax incentives, and interagency liaisons to accelerate exports.
- National Security Compliance: SEMI's comments emphasize robust compliance programs, cybersecurity, supply chain security, and risk-based licensing to prevent misuse or diversion of AI technologies.
- Global Competitiveness and Standards: SEMI urges rapid implementation, international promotion of U.S. AI technologies, and leadership in global standards to ensure interoperability and trusted adoption worldwide.
SEMI is grateful for the feedback provided by our member companies in developing this comprehensive response to the Department's RFI.
Visit SEMI Global Advocacy to learn more about public policy efforts and developments as well as how your company or organization can get involved.
Ben Kallen is Sr. Manager, Public Policy & Advocacy at SEMI.
