MediumV Technology Geopolitics & AI28 October 2026, Wednesday
Solidigm makes a 45 billion dollar US plant conditional on Dalian approval
Solidigm, SK hynix's US-based NAND unit, is in talks with the US Commerce Department over a new 45 billion dollar plant. According to Bloomberg on 27 October, the company is tying the decision to Washington's approval to ship equipment to its fab in Dalian, China.
Korea JoongAng Daily, citing Bloomberg on 28 October, reported that Solidigm told the Commerce Department total investment could rise to 100 billion dollars. New York is among the leading candidates, and construction could begin in 2027. The company argues that upgrading its Dalian NAND fab would finance and accelerate the new US facility. Solidigm declined to comment on the talks and confirmed only that it is searching worldwide for a site for a new NAND plant. How the department views the licence request as of 28 October could not be verified.
The weight of the condition dates back to August 2025. That month Washington revoked the validated end-user (VEU) status of Samsung Electronics and SK hynix. VEU was a blanket authorisation that let equipment be shipped to a specified foreign facility without a separate licence for each shipment. According to Silicon UK, SK hynix, Samsung and TSMC have since applied to the US once a year for every equipment upgrade at their Chinese fabs. Solidigm's stance shows an annual licence being put openly on the same table as a US investment pledge for the first time. Parent company SK hynix had dropped a planned 10 billion dollar IPO of Solidigm a week earlier.
Talay assessment
Bottom line
Solidigm's condition shows export controls turning from a list of prohibitions into a bargaining table that reopens every year. If Washington grants the Dalian licence, a 45 billion dollar investment will in effect have been traded for capacity growth in China. With the department's answer unknown, the most likely path is a slow decision tied to the annual licence renewal and the truce calendar.
Likely effects
- Korean memory makersUncertain1–6 months
If the Dalian licence is linked to an investment pledge, annual licence applications for Samsung and SK hynix fabs in China could become a similar negotiation.
- US NAND capacityPositive6 months+
If the investment goes ahead, a large NAND production facility will be built in the US; a 2027 construction start still depends on the licence decision.
- Foreign fabs in ChinaUncertain1–6 months
Approving an upgrade in China would mark a softening of the US line of freezing foreign capacity there, and would set a precedent for TSMC's application.
Possibilities, ranked
- 1Drawn-out bargaining55%
The department leaves the decision to the annual licence calendar and the truce talks, and no investment decision is announced before the end of 2026.
Watch: A site selection or final investment decision from Solidigm or SK hynix
- 2Trade-off approved30%
The Dalian upgrade is approved and Solidigm announces a plant in New York or another state.
Watch: A Commerce Department statement on the Dalian equipment licence
- 3Licence refused15%
Washington blocks capacity growth in China, and the investment shrinks or moves to another country.
Watch: Solidigm announcing a site outside the US
Probabilities are calibrated judgement based on the sources, not measurement, and are revised as new information arrives. Not investment advice.
Market reaction
Indicators affected
- Proposed US investment▲ $45bn
- Possible total investment▲ $100bn