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Rules of the Game · Indo-Pacific · Export Controls

Huawei Bypasses US NAND Sanctions With Die-on-Board Packaging; 122TB SSD Reaches Market

Huawei developed a proprietary die-on-board packaging technology that mounts NAND dies directly onto SSD circuit boards, allowing the company to increase storage capacity without relying on high-layer-count 3D NAND chips subject to US export controls. The technique enables Huawei to produce a 122TB SSD using less-dense NAND dies, circumventing the sanctions restrictions that blocked access to American-designed advanced NAND architectures.
AI synthesis, editor-reviewed · 1 source · May 23, 2026 · Confidence medium (one outlet)
Photo: Tom's Hardware

The real constraint for US policy is now not what Huawei can design, but how many packaging engineers and substrate fabrication lines China can dedicate to non-standard NAND integration.

If this approach requires custom PCB layouts and die-bonding equipment that only a handful of fabs can execute, the bottleneck shifts from semiconductor design (where BIS controls are effective) to advanced packaging infrastructure — a domain where China has fewer chokepoints but more flexibility to develop in-house.

Intel's packaging division and Amkor will watch whether US allies in packaging (Japan, South Korea, Taiwan) face pressure to restrict die-bonding services to Chinese customers.

WHY IT MATTERS

Huawei has demonstrated a working technical workaround to a core US export control mechanism — not a theoretical fix, but a shipped product.

The Commerce Department's NAND restrictions assumed that layer-count and die density were the binding constraints on capacity; Huawei's solution decouples capacity from density by exploiting packaging geometry instead.

This means the next round of US export controls will need to target packaging technology and die-mounting architecture, not just NAND specifications — a much harder enforcement boundary to define and police. Watch whether other Chinese firms (ByteDance, Alibaba, Baidu) adopt similar techniques for internal SSD sourcing, which would signal the workaround is reproducible and cost-effective at scale.

WHAT THIS DOESN’T TELL US

What is the actual production volume of this 122TB SSD, and is Huawei selling it domestically only or attempting export? The article doesn't specify whether this is a high-volume product or a proof-of-concept.

Sources: Tom's Hardware
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