Regarding Proposed US Restrictions on RISC-V

A bipartisan group of 18 lawmakers in the US Congress have recently amplified a request to the White House and the Secretary of Commerce to place restrictions on Americans working with RISC-V (see also the initial request from the Senate) in order to prevent China from gaining dominance in CPU technology.

The request is facially misguided; any restrictions would only serve to reduce American participation in an important emerging technology, while bolstering ARM’s position as an incumbent near-monopoly provider of embedded CPUs.

When the first report came out, I hoped it was just a blip that would go away, but with the broader bi-partisan group asking for restrictions, I felt I could no longer just stand by and watch: I am an active participant in the RISC-V ecosystem. I’m also subject to US law.

I did the one thing any American can do, which is write a letter summarizing my thoughts on the issue, and sending it to the White House, Department of Commerce, and the relevant members of Congress. Unfortunately, I don’t have a PAC, lobbyists or any sort of high-level connections to US politicians, so I don’t have much hope the letter will be received in time.

However, I do have a blog. I’m posting a copy of the letter I sent to the White House here, in far-flung hopes that maybe someone with more political connections than I might pick it up and send it on.

Finally, if you disagree with my stance or have a different perspective, I also encourage you to send a letter expressing your thoughts to various government officials. It doesn’t have to be “my way”, but a show of broad public interest in the topic may at least encourage policymakers to think a bit more carefully about the issue, and to hear out more perspectives.

The Letter

To President Biden and the White House staff:

Recently, a letter was sent to the White House and the Secretary of Commerce by 18 lawmakers asking how the US plans to prevent China “from achieving dominance in … RISC-V technology and leveraging that dominance at the expense of US national and economic security”.

I am a Michigan-born American with a PhD from MIT in electrical engineering. I’m also a small business owner who designs and manufactures electronics. I am writing to urge you to not place any restrictions on the sharing of RISC-V technology.

My products’ CPUs are based on the open source RISC-V standard. RISC-V’s openness specifically benefits small businesses such as mine. I get tools and designs from the open source community, and I contribute my improvements back to the pool. Barrier-free participation in this vibrant open source ecosystem keeps overhead low, allowing me to be competitive in the cutthroat hardware business.

Like the Internet, RISC-V is already a global phenomenon. There are already prolific contributions from the EU, India, China, and more [1]; the US is not the sole proprietor of RISC-V implementations. I use an implementation of RISC-V called the VexRiscv, which is developed in the EU. Any barrier for US persons’ participation will only slow American progress in developing and adopting this technology. It will have an effect opposite of that intended by lawmakers.

A further subtlety is that RISC-V is simply a standard. It defines a set of words used to tell a chip to do something, similar to how we rely on a dictionary to define the meaning of English words. Just as one can write secret documents using openly defined words, designs using the RISC-V standard can be proprietary, even if the standard is open. The benefits of open standards are so well established that the US has an entire agency – NIST – to promote American innovation and industrial competitiveness by publishing open standards.

Furthermore, it is not practical to police the use of an established standard: once a book is published, it is impractical to ensure that none of America’s enemies obtain a copy of it. This has long been a trade-off of American innovation philosophy: we can freely exercise our First Amendment rights to share ideas, creating a vibrant intellectual exchange, even at the risk of others benefiting from reading our textbooks, journals and patents.

I believe this trade-off has been in our favor. With every exchange – even with potential competitors – we learn more. Chilling our freedom of expression to achieve administrative outcomes is a page out of other more oppressive regimes’ playbooks: it is fundamentally un-American to restrict the flow of ideas.

In summary, any restrictions placed on US persons sharing RISC-V technology would only serve to diminish America’s role as a technological leader. Over-broad restrictions could deprive educators of a popular tool used to teach students about computers on American campuses, for fear of also accidentally teaching to an embargoed entity. And even narrow restrictions on RISC-V could deprive US tech companies with any potential exposure to the Chinese market of access to a cost-effective, high-performance CPU technology, forcing them to pay royalties to the incumbent near-monopoly provider, ARM Holdings plc – a company that isn’t American. This weakens American competitiveness and ultimately harms the US’s best interests.

If the administration agrees that RISC-V is a technology so critical to US economic and military interests that it deserves special attention, instead of trying to restrict its expression with a federally-mandated licensing regime, it should invest in programs to develop more home-grown American RISC-V chip maker success stories. It is already within the four corners of existing US legal framework, and the RISC-V contractual framework, for companies to choose to develop proprietary implementations of RISC-V CPUs. The US has strong precedents for companies navigating the boundaries of open standards and finding success without the need for federal guidance: Intel and AMD are American industrial juggernauts built around proprietary implementations of an otherwise openly documented “x86” computer standard. What the US needs is an American answer to ARM Holdings plc’s monopoly, and that answer comes from investing in US companies that embrace RISC-V.

President Biden, I urge you: have faith in American innovation. Have faith in American values. Do not place any restrictions on the sharing of RISC-V technology. We can work together to build more US chip maker success stories, while embracing the American value of freedom of expression!

Very truly yours,

Andrew ‘bunnie’ Huang
An American Hacker, Maker, and Author

[1] https://github.com/riscvarchive/riscv-cores-list

19 Responses to “Regarding Proposed US Restrictions on RISC-V”

  1. m says:

    I’m really pleased that you have written this letter. I hope that other individuals and large tech companies will do so too.

  2. Daniel Franzini says:

    I thought that the past lessons learned from the US crypto exporting policies back in the 90s were well understood. Sad to hear they are not. What amazes me the most is the simple fact that people that wrote this kind of stupidity neither have absolutely no clue about how technology works nor are willing to hear people that does. I hope the US government really listens to what Bunnie is saying.

  3. Willem says:

    I also wonder how the US would envision to regulate something which was developed by an internationally diverse group of people, and owned by an organisation registered in Switzerland.

    • Max says:

      They don’t (because they can’t) regulate the RISC-V standard, or any part of it, they just want to regulate the US companies that produce and sell processors based on this architecture (or even included as secondary processor in an x86 or ARM chip).
      RISC-V architecture has many advantages like great flexibility, openness, community, etc. (also some great progress have been done on energy consummation that would, if the power is scaled to most mainstream ARM chips (powering phones, etc.), can greatly increase the battery life) so I guess that US government is thinking that US can have the same advantage (pressuring the market and keeping the “best bits” for them, like with supercomputers with IBM Summit and Peak) over RISC-V that they’ve got over x86. They (Nvidia) missed the opportunity to buy a fair share of ARM, that since more than 10 years, is eating most of the market (even a little in supercomputers).
      Now, I imagine that they fear that Chinese processors would be not standardized (as anybody can create custom RISC-V extension freely, which is close to impossible with x86, even with a great amount of money, and still very expensive with ARM), so theses processors would be good candidates to Chineses backdoors once sold in US.
      It’s quite ironic from US government, I must say.

  4. Toby says:

    All in agreement, but there seems to be a strange typo in the intro paragraphs to the letter itself “The request is facially misguided” Basically? Farcically? It’s definitely misguided, just not sure exactly which way…

    • David says:

      This is a legal term that means “on its face; as it appears”.

      • Toby says:

        Ah, interesting, I guess I’d think that even in legal circles that wouldn’t be preferable to “clearly misguided” or “obviously misguided” but then I am not a lawyer. Thanks!

  5. Orzel says:

    Hi,

    As I understand American politicians, it would have been tremendously useful to mention the fact that risc-v was, originally, created in the USA.

    (I’m not american)
    Greetings !

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  8. 7alken says:

    added this line to my temporary license:

    One thing: This will be NEVER allowed to be used by anyone as any kind of weapon – financial, lethal, psychological, any other, JUST NEVER. FOREVER.

  9. 7alken says:

    (as I recently found, some risc-v engine was already integrated to at least one crypto coin scam/weapon)

  10. i3lue Fire says:

    Thanks for this. I am not a fan of restricting open standards or any open hw/sw.

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