U.S. 65% Domestic Content Rule May Reshape Value Distribution in China's Optical Supply Chain
nashnova research
Morgan Stanley estimates the US may require 65% US-sourced component value in next-gen 3.2T optical transceivers — not a ban on Chinese assemblers, but a rule that redirects the most profitable component dollars to American suppliers.
What does the rule actually require?
The threshold is not about where a module is built. It is about where the high-value parts come from — US-supplied components must account for at least 65% of the product's bill of materials (BOM — the full parts list for one finished unit).
Morgan Stanley estimates that a 3.2T optical transceiver (a module that converts electrical signals to light and back — a critical building block in data-center networking) using Marvell's DSP (digital signal processor — the core chip that encodes and decodes the signal) plus a Lumentum or Coherent laser could clear the bar.
This means → what decides market access is the nationality of the parts, not the address of the assembly plant.
Are Chinese firms locked out — or repositioned?
Module design, manufacturing, assembly, and testing — Chinese firms can keep these roles.
But DSPs and lasers — the two highest-margin components — will tilt toward US suppliers. In plain terms = Chinese firms still get orders, but the parts where the real money sits must come from America.
Morgan Stanley notes the US currently lacks the capacity to replace Chinese assemblers quickly; Reuters previously cited industry warnings that a sudden full cut-off could disrupt US AI data-center buildouts.
This reflects Washington choosing a middle path: let China keep assembling, while steering high-value component revenue back to American firms.
Why target 3.2T first — not 800G or 1.6T?
800G and 1.6T products are already shipping at scale; restricting them now would hit existing supply chains hard.
3.2T is expected to enter higher-volume production around 2028, with broader adoption in 2029 — even if the US begins drafting rules in 2026, the real revenue impact lands later.
This means → the rule targets procurement structure for the next generation, giving all sides a two-to-three-year adjustment window: the US to expand capacity, Chinese firms to restructure component sourcing.
What does this mean for Chinese optical-module stocks?
Share prices of Chinese optical-module and component suppliers have already shown notable volatility on related reports.
The market had priced these companies on two pillars: expanding AI data-center demand and progress in localizing DSPs, lasers, and other key components.
In plain terms = if the 65% rule lands, Chinese firms can still win orders, but the room for locally sourced components shrinks and the profit split changes directly — they earn assembly margins, not core-component margins.
市场有风险，内容仅供研究参考，不构成投资建议。