采购受出口管制物项

港股IPO招股书披露先例 · 28 家公司,29 项

此类事项一般指申请人采购美国原产或受美国出口管制法规规限的芯片、软件及零部件,或向被列入管制清单的供应商采购的情形。招股书通常于概要、风险因素、业务及财务资料章节披露采购金额与占比、物项归类及许可证要求,申请人多援引法律顾问意见说明无需许可或无重大不利影响,并辅以提前备货、转向替代或国产供应商、交易对手筛查等缓释措施。

2026-03-26Application Proof
四维智联(南京)科技股份有限公司AutoAI (Nanjing) Technology Co., Ltd.

部分车规级SoC芯片受美国出口管制规限

During the Track Record Period, the percentages (based on number of units sold) of SoCs incorporated into our solution sold that were produced in mainland China were 17.1%, 19.1% and 52.1%, respectively.

Business · 第 161 页

Thus, as advised by our U.S. export controls counsel, taking the suppliers’ confirmations and our understanding of relevant rules, the Company is of the view that there is no license required for our procurement of those chips subject to the EAR.

Business · 第 163 页

Nevertheless, according to Frost & Sullivan, there are more than 25 alternative domestic suppliers who provide SoCs with comparable quality and price.

Business · 第 163 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看
2026-03-18Application Proof

向美国采购软件涉及美国出口管制

During the Track Record Period, we procured certain software and services from the U.S., primarily software used in developing our AOS for automotive-grade chips. The aggregate procurement amount was RMB43.3 million, representing approximately 1.8% of our total procurement during the Track Record Period.

Business · 第 175 页

As advised by the U.S. Export Control Legal Advisor, a China-based company's purchase of U.S.-origin software does not, in itself, constitute an "export" under the EAR.

Business · 第 175 页

Nevertheless, according to CIC, there are more than 15 alternative domestic suppliers who provide such software services with comparable quality and price.

Business · 第 175 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看
2026-02-27Prospectus
南京埃斯顿自动化股份有限公司ESTUN AUTOMATION CO., LTD02715.HK

美中贸易紧张及美国出口管制影响有限

During the Track Record Period, our revenue derived from the U.S. was insignificant, and products sold in the U.S. were primarily manufactured in Europe rather than exported directly from Chinese Mainland.

Summary · 第 27 页

Our Directors are of the view that recent geopolitical developments and U.S.-China trade tensions have not had a material adverse effect on our operations or financial performance.

Summary · 第 27 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看
2025-12-30Prospectus
上海天数智芯半导体股份有限公司Shanghai Iluvatar CoreX Semiconductor Co., Ltd.09903.HK

美国出口管制致供应商F暂时中断供货

For example, the U.S. Department of Commerce issued an ‘‘Is Informed’’ letter to Supplier F in November 2024, imposing immediate export restrictions to prevent Supplier F’s shipment of certain types of advanced semiconductor products to China, particularly those used in AI applications.

Business · 第 220 页

As a result of the foregoing, we experienced a temporary disruption in supply of certain types of co-packaged integrated circuits used for several of our products from late November 2024 to early February 2025.

Business · 第 220 页

This temporary supply interruption did not materially affect our operations primarily because we had proactively built up and maintained sufficient inventory levels to fulfill customer commitments; the timing of the disruption coincided with typical seasonal industry slowdowns in customer demand; and importantly, we had already initiated and made substantial progress in implementing alternative supply arrangements as part of our routine supply chain risk management strategy.

Business · 第 220 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看
2025-12-30Prospectus
北京智谱华章科技股份有限公司Knowledge Atlas Technology Joint Stock Company Limited02513.HK

公司及九家附属公司被列入实体清单

On January 16, 2025, our Company and nine of our subsidiaries were added to the Entity List administered by the BIS.

Summary · 第 22 页

During the Track Record Period and prior to the Entity List Addition, we purchased certain computing hardware containing U.S.-origin AI chips subject to the EAR in compliance with the relevant export control rules and regulations and we have not procured any items subject to the EAR since August 2023.

Business · 第 214 页

In light of the above, the Entity List Addition has not had, and our Directors are of the view that (assuming there is no expansion of the EAR restrictions or the scope of the Entity List Addition) it will not have in the near future, any material adverse impact on our business and financial performance.

Business · 第 214 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看
2024-12-18Prospectus
英诺赛科(苏州)科技股份有限公司InnoScience (Suzhou) Technology Holding Co., Ltd.02577.HK

美国出口管制及对外投资限制影响

The purchase amount of such 3B001.A items was approximately RMB245.7 million, RMB4.4 million, RMB0.7 million and RMB0.2 million in 2021, 2022, 2023 and the six months ended June 30, 2024, respectively, accounting for 13.7%, 0.5%, 0.1% and 0.1% of our total purchases in the respective periods.

Business · 第 294 页

As advised by our Export Control Consultant, considering that the U.S. Department of the Treasury does not propose to apply the Final Rule retroactively, existing investments made by U.S. persons in our Company (including investment by Dr. Luo) or investments made before the implementation of the forthcoming regulations are not expected to be affected.

Business · 第 295 页

As advised by our PRC Legal Advisor, as of the Latest Practicable Date, considering that (i) we primarily procured trimethylgallium for production, as gallium is not a direct raw material used in our production, and manufactured GaN product is not expressly set out in Announcement No.23 or Announcement No. 46, and (ii) our main business does not include the export of any items listed in the Announcement No. 23, nor does it include any export of dual-use items to the United States listed in the Announcement No. 46, Announcement No. 23 and Announcement No. 46 are not expected to have material adverse impact on our business, financial condition and results of operations.

Business · 第 296 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看
2024-12-17Prospectus
深圳佑驾创新科技股份有限公司Minieye Technology Co., Ltd02431.HK

美国芯片出口限制及采购替代

In 2021, 2022, 2023 and the six months ended June 30, 2024, the amount of semiconductors incorporated into the Group's solutions that were sourced from the U.S. was approximately RMB52.1 million, RMB14.4 million, RMB21.9 million and RMB9.6 million, respectively, representing 20.9%, 5.3%, 5.6% and 6.7% of the total amount of semiconductors procured during the same period.

Business · 第 307 页

Aware of the U.S Chip Export Restrictions, we gradually reduced the use of semiconductors sourced from the U.S. and formulated plans to replace such semiconductors with semiconductors sourced from PRC or other countries.

Business · 第 307 页

Our Directors are of the view that the restrictions imposed by the EAR, including the BIS 2022/23 IFRs, had not negatively impacted our operations or financial performance as of the Latest Practicable Date.

Business · 第 307 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看
2024-07-31Prospectus
黑芝麻智能国际控股有限公司Black Sesame International Holding Limited02533.HK

美国出口管制新规对代工及采购安排的影响评估

On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released an Interim Final Rule (the 2022 Rule) that implemented several new export controls to restrict China’s access from the U.S. and overseas sources relying on U.S. technology to certain advanced computing technology, semiconductors, and related items used in the manufacturing of semiconductors.

Business · 第 295 页

K&L Gates, our legal advisors as to U.S. export control laws, confirmed that during the Track Record Period, the arrangements between the Group, Shanghai International and TSMC are not materially impacted by any U.S. export restrictions currently in effect.

Business · 第 276 页

The Company’s sales transactions with Shanghai International and TSMC were not significantly impacted by the new U.S. export control restrictions, since the restrictions are broadly inapplicable to the products involved.

Business · 第 276 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看
2023-12-27Prospectus
速腾聚创科技有限公司ROBOSENSE TECHNOLOGY CO., LTD02498.HK

美国拟调查中国激光雷达企业及涉美芯片采购

Our procurement of semiconductor chips from U.S. suppliers accounted for 83.0%, 39.5%, 68.5% and 68.1% of the total procurement amount of semiconductor chips in 2020, 2021 and 2022 and the six months ended June 30, 2023, respectively, while procurement from PRC suppliers accounted for 17.0%, 60.5%, 31.5% and 31.9% in the same periods, respectively, based on our management accounts.

Business · 第 204 页

As of the Latest Practicable Date, we had not been added to any of the Relevant Lists, nor had there been any changes to the scope of U.S. export controls solely as a result of this request.

Summary · 第 16 页

As of the Latest Practicable Date, based on the scope of the proposed regulation and our Company’s confirmation that our LiDAR products are intended for commercial use only, our legal advisor as to U.S. export controls, sanctions, customs, and foreign investment laws and regulations is of the view that even after it takes effect, the process is not likely to prohibit investment in our Company or the sale of our products.

Business · 第 204 页
公司的解释、律师意见及原文页码定位:在 Matters 中查看

Tell us