Mechanism · Chip registries and manufacturing records

Evidence & limits

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R1Proposed for a checkable record of which chips were made and who declared owning them

Registry and record-commitment designs are public, but none has been built or tested.

Assessed use: a checkable record of which chips were made and who declared owning them

Rubric assessment

  • R1 met: Baker et al. describe an AI chip registry for ownership declarations, with sampled chain-of-custody checks from manufacture to destruction, and state the goal and assumptions 1. Avellar and Grunewald describe how a regulator could run a registry of chip ownership and use it for random return requests 2. Cankaya proposes cryptographic commitments to foundry chip-ID records 3.
  • R2 not met: as of September 2026 no AI chip registry or manufacturing-record commitment has a public implementation, and no end-to-end results have been published 1 2 3. Export documentation checks are established practice, but they are not a registry, and Avellar and Grunewald rate them low in effectiveness as a verification tool 2. Ansari rates registry systems as near-term, not deployable now 6.
Gaps to the next level
  • A public pilot registry or published commitment to manufacturing records at realistic scale.
  • End-to-end results for sampled chain-of-custody checks, including how hard-to-spoof IDs are read and matched.
  • An adversarial evaluation of record falsification, forged serial numbers and unrecorded chips.

Assessed 2026-09-25 against rubric v1.1.

Evidence

  • Designs only. Baker et al., Avellar and Grunewald, and Cankaya publish designs; none reports an implementation 1 2 3.
  • Feasibility ratings. Ansari rates registry systems as near-term 6. He rates trade-data analysis as deployable now, citing work that uses existing customs data to find circumvention patterns 6.
  • Export-control ratings. Avellar and Grunewald rate export documentation checks as relatively established but low in effectiveness, and random return requests from a registry as novel and high in effectiveness 2.

Limitations

  • Unrecorded chips. Chips outside the record are not covered, and a fraudulent original record would mean unregistered chips were made in advance 3. Reconstructing earlier production depends on supplier records 7.
  • Forgery. Documents can be forged, and serial numbers on chips and racks may be forgeable 2. In a December 2025 prosecution, the US Justice Department alleged that workers replaced GPU labels with a fictitious brand before export or attempted export 10.
  • Insider tampering. Records can be altered before they are committed 3.
  • Limited reach. Covering re-exports would need cooperation from re-exporters and foreign governments, which may not be feasible everywhere 2.
  • Custody versus location. A commitment fixes what was made, but tracking where chips are needs inspections or location checks 1 3.

Known flaws

Blockers

  • No AI chip registry operates, and covering re-exports would need cooperation from re-exporters and foreign governments that may not be feasible everywhere.

  • Linking records to physical chips needs hard-to-spoof unique IDs and inspections.

  • Chips produced before a registry starts must be reconstructed from supplier records.

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