Sources: CXMT has begun producing HBM3E memory chips in small quantities and plans to expand production in 2027, a major advance for China's chip industry (The Information)

China's top DRAM manufacturer, ChangXin Memory Technologies (CXMT), has initiated legal action against the U.S. Department of Defense (DoD) to challenge its classification as a company linked to China's military. Reuters reports on this legal dispute, which alleges that the Pentagon's decision lacks evidence, violated due-process, and has negatively impacted CXMT's business and reputation.

CXMT asserts that it has no connection to the Chinese People's Liberation Army (PLA) and contends that the Pentagon's decision was based on weak evidence, violated due-process requirements, and caused significant damage to its business and reputation. The Pentagon had initially classified CXMT as a Chinese military company in January 2025, during the administration of President Joe Biden. The Trump administration subsequently upheld the classification when the DoD updated the list in June.

In response to the classification, CXMT spent over a year providing information to the DoD in an attempt to overturn the designation. However, the company claims that the DoD published a notice in February stating that CXMT would be removed from the list but later withdrew that notice without providing an explanation.

CXMT maintains that its DRAM products conform to JEDEC commercial standards and do not meet the requirements for military-grade semiconductor components, which involve aspects such as temperature, packaging, testing, and military oversight. Additionally, the company argues that if its products were manufactured in the U.S., they would be classified for purely civilian use and that it holds no licenses for military product manufacturing.

The Pentagon's classification of CXMT as directly affiliated with the Ministry of Industry and Information Technology (MIIT) and indirectly affiliated with the State-owned Assets Supervision and Administration Commission of the State Council (SASAC) has raised concerns about its potential restrictions on U.S. government contracts. CXMT seeks to protect its business interests by challenging the designation, as it can negatively affect commercial relationships and reputation.