An Entity List designation would cut CXMT off from US chipmaking tools and complicate any foreign buyer's plans, including Apple's reported interest in its memory for iPhones and Macs.
Senator Tom Cotton has asked Commerce Secretary Howard Lutnick to add CXMT, the Hefei-based maker of DRAM memory chips, to the Bureau of Industry and Security’s Entity List, a step that would sharply limit its access to American technology. The Arkansas Republican, who chairs the Senate Intelligence Committee and the Senate Republican Conference, sent the letter on November 12. CNBC, which obtained it first, cited Counterpoint Research figures showing that CXMT’s share of global DRAM revenue rose from 4% to 10% in the year to the second quarter of 2026.
Cotton’s press release says the company "poses a growing risk to our economic prosperity and military superiority." It also goes further than a listing. Cotton asked Commerce to use its information and communication technology services (ICTS) office "to explore a prohibition on sales of CXMT products" in the United States, arguing that American and allied alternatives are available.
The letter is a request, and neither Commerce nor CXMT has answered it. The Commerce Department and CXMT did not immediately respond to CNBC. Reuters also reported the letter, which Cotton sent on Thursday. The pressure lands on a secretary already under fire for not adding Chinese companies to the list.
Cotton wants CXMT barred from US tools and from US buyers
CNBC said a listing would significantly restrict US companies’ dealings with CXMT and block its access to US technology. Cotton wants the designation to cover semiconductor manufacturing equipment and tools for any CXMT plant. Today, according to his release, the bureau’s end-use controls restrict exports of a range of advanced technologies only to some CXMT plants. Congress already limited federal purchases of CXMT products in the fiscal 2023 National Defense Authorization Act.
Cotton’s office also points to the Pentagon’s Section 1260H list of Chinese military companies, which already names CXMT, and says the company is central to China’s Military-Civil Fusion strategy. Kyle Chan, a fellow at the Brookings Institution, told CNBC that the 1260H list carries few practical restrictions: "It’s not a list that has that much teeth to it, in terms of restrictions to U.S. companies." An Entity List designation, he said, "basically means that U.S. companies are not allowed to do business with that entity-listed company."
The letter also takes aim at CXMT’s push into high-bandwidth memory (HBM), the stacked memory that sits beside AI accelerators. Citing reports that CXMT will begin producing HBM3E chips, it says their manufacturing yields "hover at 20 percent." EastFrontier reported last month that CXMT plans to start HBM3E production despite yields as low as 20%, citing Reuters, which put yields at 20% to 30%.
The bigger stake is who buys CXMT memory
CXMT is the world’s fourth-largest DRAM producer, behind Samsung, SK Hynix and Micron, the only three companies that make HBM. The Chinese company listed on Shanghai’s STAR Market in July, and CNBC noted that its shares soared enough to make it, for a time, the most valuable company listed in China.
Its customers are the pressure point. CNBC recalled a Wall Street Journal report of August 9 that Apple was considering CXMT memory for iPhones and Macs during the AI-driven memory shortage, a plan an Entity List designation could upend. Chan said Washington’s concern is that even purchases of CXMT’s products "would help China get further down the road towards HBM," as part of a wider effort to slow China’s chipmaking.
CXMT’s business is moving toward the server market that AI is driving. On the same day, IT Home, citing information from CXMT, reported that its DDR5 memory dies have moved from 24Gb to 32Gb. Its server modules now run from 32GB to 128GB at speeds of 5,600 to 8,000Mbps, and a newer high-speed module type, MRDIMM, which fits standard DDR5 server slots, comes in 128GB and 192GB versions at up to 12,800Mbps. Vice president Luo Xiaodong said servers now account for more than half of market demand. CXMT expects revenue to keep growing in the fourth quarter and DRAM supply to stay tight.
Commerce has added no companies to the list in more than a year
The request reaches Lutnick at a difficult moment. A longer Reuters report said senior White House officials were discussing whether to push him out after a spy scandal led Jensen Huang to step down as Nvidia’s chief executive. A White House official said President Donald Trump "maintains complete confidence in the secretary."
Reuters also recalled that in June the administration held off on adding DeepSeek, CXMT and more than 100 other companies flagged as security risks to the Entity List. No additions have been posted since October 2025, the longest gap in more than a decade. The same report said Senators Elizabeth Warren and Chris Coons had asked Lutnick and other officials to preserve documents on Nvidia’s chip exports to China, and that Senator Ron Wyden and Representative Richard Neal are investigating the approval of those sales.
Cotton’s letter puts a senior member of the president’s own party behind a CXMT listing. The signal to watch is the first new Entity List posting since October 2025, and whether CXMT’s name is on it, or any ICTS inquiry into sales of its memory in the United States.