Talks on $45 Billion Investment: A Potential New US NAND Plant
2026-10-28
Solidigm, the California-based NAND flash subsidiary of SK hynix, is in talks with the US Department of Commerce to invest $45 billion in building a new NAND flash wafer fab in the US. If realized, it would be the first large-scale flash memory production facility on US soil, with potential sites including New York State and other states, and construction possibly starting as early as next year. But Solidigm has set a precondition: the US government must first approve shipments of equipment to its Dalian plant in China to complete upgrades of existing facilities.
Dalian First, Then the US
Solidigm's logic to the US side is that upgrading the Dalian plant would help fund construction of the new US plant and accelerate the US project. This is based on existing available capacity at the Dalian site. SK hynix has a wafer production area in Dalian called “Mod B”; built in 2023 but left with equipment installation incomplete due to the memory market downturn, it still has substantial space for additional tools. In the current environment of tight NAND supply and rising prices, activating this idle capacity with relatively limited equipment investment would generate cash flow faster than building a new plant from scratch.The key obstacle to this arrangement is export controls. In August 2025, the US Commerce Department revoked the validated end-user authorization for Samsung Electronics and SK hynix, after which the Dalian plant must apply case by case to use US equipment. When revoking the exemptions, the US side indicated that in principle it would approve only equipment needed to keep existing plants running, and did not expect to approve expansion or technology upgrades. In December 2025, the US issued 2026 licenses but set caps on equipment quantities. New equipment licenses for 2027 have not yet been issued, while Solidigm has already submitted purchase applications for more equipment for the Mod B area.
IPO Withdrawal and Funding Path
Previously, on October 23, SK hynix announced it was suspending Solidigm's US IPO plan and shelving the accompanying pre-IPO financing.
The IPO had been one of Solidigm's important channels for raising funds for the US plant. With that path paused, the need to generate cash flow through increased production at the Dalian plant and use transitional capacity to support the US project has risen. SK hynix is also in talks with Intel to lease part of its Ohio plant space, similarly seeking transitional options to reduce upfront capital expenditure.
Strong Demand and Policy Variables
Solidigm's investment condition is directly related to the supply-demand landscape of the NAND market. TrendForce data shows that in 2026 major NAND suppliers have almost no new capacity, AI demand remains strong, and the full-year supply shortage is difficult to ease.
But tight supply and demand does not automatically translate into policy relaxation. While pushing Samsung and SK hynix to build plants in the US, the US Commerce Department remains cautious about approving equipment needed for expanding or upgrading Chinese plants. In practice, the approval pace and final scope of Solidigm's plan are in US hands.
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