Apple's plan to procure China-made memory has sparked renewed friction with the U.S. Congress. On June 27, 2026, the Financial Times reported that Apple has been lobbying the Trump administration to purchase memory from China's ChangXin Memory Technologies (CXMT). Representative John Moolenaar told the paper that partnering with a Chinese military company would be a "serious mistake."
However, what the FT reported was Apple's lobbying activity and the lawmaker's opposition—not the introduction or passage of new legislation naming Apple specifically. No blanket purchase ban has been announced that would immediately halt Apple's private-sector procurement. What is already legally settled is a measure naming CXMT and Yangtze Memory Technologies (YMTC) that excludes equipment containing chips from either company from the U.S. federal government's procurement network. The effective date is December 23, 2027.
While the grace period before implementation leaves Apple with options, it also complicates adoption decisions. Even if China-made memory can be used in products destined for the Chinese market, the same component configuration may not be sellable to the U.S. federal government. The issue has shifted from whether a purchase is permissible to whether, for each product, the origin of components can be certified and supply chains segmented according to the buyer.
A Mechanism to Exclude from Federal Procurement Exists Ahead of New Legislation
The FT reported, citing six people familiar with the matter, that Apple sought the administration's approval to purchase from CXMT. According to the paper, Apple is not currently prohibited from purchasing memory from CXMT or YMTC itself. Apple, CXMT, and the White House reportedly did not respond to the paper's inquiries. There is no indication that a contract has been signed or mass production adoption decided.
U.S. regulations targeting China vary in effect even among what might be called the same "lists." On June 10, 2026, the Department of Defense designated CXMT and YMTC as "Chinese military companies" under Section 1260H of the National Defense Authorization Act. The notice explains that CXMT has a direct relationship with China's Ministry of Industry and Information Technology (MIIT) and indirect relationships with entities such as the State-owned Assets Supervision and Administration Commission (SASAC) of the State Council. For YMTC as well, indirect ownership by SASAC and relationships with MIIT and others were cited.
The 1260H designation represents the Department of Defense's determination regarding both companies' relationships with the Chinese government and military-industrial complex. However, this designation alone does not make purchases by private U.S. companies uniformly illegal. The Commerce Department's Entity List is a separate system, imposing strict licensing restrictions on exporting, re-exporting, or transferring domestically items subject to the Export Administration Regulations (EAR) to listed companies. YMTC was added to the Entity List in December 2022, but the Entity List, too, was not designed as a mechanism to comprehensively ban the import of finished products.
This is why Apple is seeking the administration's outlook regarding CXMT. If CXMT were added to the Entity List after adoption, strict licensing requirements would apply to the supply of manufacturing equipment, design software, and technology subject to the EAR. The question of whether a purchase is possible now does not align with the question of whether supply can be sustained throughout a product's lifecycle.
Federal Configuration Review Begins December 23, 2027
The U.S. Congress had already named CXMT, YMTC, and Semiconductor Manufacturing International Corporation (SMIC) in Section 5949 of the National Defense Authorization Act for Fiscal Year 2023, enacted December 23, 2022. The law prohibits the federal executive branch from procuring electronic products and services containing semiconductors from the named companies starting five years after enactment—that is, from December 23, 2027 onward. For critical systems, the regulation extends even to devices using other electronic products that contain the targeted semiconductors.
The proposed rule for FAR Case 2023-008, published on February 17, 2026, translates this prohibition into practice. It covers commercially available electronic products, COTS (commercial off-the-shelf) items, micro-purchases, and commercial IT and telecommunications services. Prime contractors must conduct reasonable inquiry and certify that products and services delivered to the government do not contain the targeted semiconductors. Subcontractors are required to make the same verification, and if there are discrepancies in supplier certifications, further investigation becomes necessary.
Even consumer products like the iPhone, iPad, and Mac are commercially available electronic products when delivered to federal agencies. If Apple or a reseller proposes a configuration containing CXMT-made DRAM or YMTC-made NAND to the federal government, it could be subject to the regulation unless an exception or waiver applies. Three possible responses for Apple can be considered: forgoing adoption altogether, excluding such components from federal configurations, or splitting the bill of materials (BOM) by region or customer. Which option Apple will choose has not been disclosed.
The proposed rule also includes transition provisions. Existing equipment acquired before December 23, 2027 will not be required to be removed, and maintenance parts and support can continue. For commercial products and services with no available alternatives, an exception exists until December 23, 2028. If compliant products cannot be obtained when needed at U.S. market prices or at prices that are not excessively high, and if it is determined that national security would not be compromised, agency heads may issue waivers of up to two years each, renewable. The proposal sets a 72-hour deadline for reporting to the government when a targeted chip is discovered. The comment period closed on April 20, 2026, but as of July 17, the rule had not yet been finalized.
CXMT's DRAM and YMTC's NAND Are Different Components
Discussing China-made memory as a single category obscures what exactly Apple is seeking. CXMT is a DRAM manufacturer, with DDR5, LPDDR5/5X, DDR4, and LPDDR4X among its official product lineup. LPDDR for smartphones and tablets serves as the main memory where apps and the OS place data during operation.
YMTC's mainstay is 3D NAND. NAND is used for storage that retains photos, apps, and OS data even after power is turned off. The company handles 3D NAND wafers and packaging, embedded memory, and SSDs, citing applications ranging from mobile devices to servers. It was future iPhone-bound YMTC 3D NAND that U.S. senators noted Apple had acknowledged considering back in 2022.
Apple's quarterly report also revealed that supply constraints and rising costs are occurring for both DRAM and NAND. The report, filed May 1, 2026, explained that supply-demand imbalances in advanced semiconductors, NAND storage, and DRAM memory are causing supply constraints and rising component costs, and predicted the situation would intensify. CXMT on the DRAM side and YMTC on the NAND side each have product lines that could potentially address Apple's procurement pressures.
At the same time, these are not components that can be swapped in immediately just because price and supply align. Each product requires verification covering power consumption, capacity, yield, and long-term supply. Furthermore, for federal procurement, supplier verification and certification are required separately from performance testing. While prime contractors can rely on subcontractor certifications absent discrepancies, any doubt raised necessitates further investigation. The more low-cost suppliers are added, the more complex the bill of materials becomes, increasing the cost of regulatory compliance.
The 2022 YMTC Precedent Shows the Likely Sequence
The political clash between Apple and Chinese memory also occurred in 2022. On September 22 that year, four senators—Mark Warner, Marco Rubio, Chuck Schumer, and John Cornyn—requested that the Director of National Intelligence conduct a security risk assessment, citing Apple's public acknowledgment that it was considering procuring YMTC 3D NAND for future iPhones. That was the moment a company's procurement consideration transformed into a bipartisan policy matter.
Subsequently, the Commerce Department added YMTC to the Entity List effective December 16, 2022, imposing a presumption of denial for licensing review on EAR-covered items. One week later, on December 23, Section 5949 was enacted, excluding semiconductors including those from CXMT and YMTC from federal procurement. The lawmakers' statements of opposition did not directly translate into a ban on private purchases. But within that same year, two systems—export controls and government procurement—were put in place, narrowing the company's options.
Whether the current CXMT reporting will follow the same path remains undetermined. However, the policy tools are already in place. If the administration adds CXMT to the Entity List before the end of 2027, Apple's considerations would become difficult from the upstream end of the supply chain. Even without additional measures, once Section 5949 takes effect, CXMT and YMTC will need to be excluded from products delivered to the federal government unless exceptions or waivers are utilized.
Three points can be narrowed down for confirmation: how much supplier investigation and exceptions the FAR final rule will retain, whether the administration will preemptively strengthen export controls against CXMT, and how Apple will define the scope of adopting China-made memory. Whether suppliers will be excluded, federal configurations separated, or exceptions and waivers utilized remains undecided. From December 23, 2027, Apple products using China-made memory will be subject to regulation when delivered to the federal government.