• U.S. Foreign Policy
• U.S. State Department
• United States
• China

Without a doubt, this change will fundamentally reshape American higher education and global scientific competition. But because the criteria—critical fields and connections to the CCP—are deliberately vague, and because the administration has declined to offer further detail about how they will be determined, how many students will be targeted remains highly uncertain.

However, by my own estimates, the policy could affect more than 150,000 of the 283,025 students from China and Hong Kong currently in the United States.

The China Initiative, which increased investigations of academics and researchers suspected of spying for China, ran from 2018 to 2022. Of the 148 individuals charged under this initiative, 88 percent were ethnically Chinese, which led to allegations that it was tantamount to racial profiling. Only 25 percent of the individuals charged were ultimately convicted—far below the typical Department of Justice conviction rate of 91 percent. The Biden administration ended the China Initiative in 2022 after failing to uncover the widespread espionage it sought to root out.

What distinguishes the Trump administration’s new approach is its shift from institutional targeting to mass screening of individuals through automated systems. Whereas previous policies focused on specific research programs or military-affiliated universities, the new plan could use algorithms to assess students’ social media posts, family connections, childhood associations, and academic fields using information from government databases and commercial data brokers.

Chinese students, who represent the second-largest international student population in the United States, are concentrated in fields and institutions that maximize their exposure to new restrictions. Geographically, the most popular states for Chinese students are California, New York, and Massachusetts, which host some of the United States’ premier research universities. Chinese students are also particularly concentrated in so-called critical fields. For instance, Chinese students earned almost 14 percent of STEM research doctorates awarded in the United States in 2021.

Widespread restriction of students from China and Hong Kong will have substantial financial consequences. By my own calculations, based on data from NAFSA: Association of International Educators and Open Doors, these students likely contributed approximately $11 billion to the U.S. economy during the 2023-24 academic year, supporting almost 95,000 jobs through the money spent on tuition and within local economies. But the innovation impact dwarfs these direct contributions: Eighty-seven percent of Chinese Ph.D. recipients from 2006 to 2015 remained in the United States as of 2017, forming the backbone of many research teams and technology start-ups.

Just how many Chinese students are affected by new restrictions will come down to how the Trump administration decides to interpret its own criteria. The U.S. State Department’s Foreign Affairs Manual defines Communist Party connections through several categories, such as providing material support to the party. The broadest potential impact, however, will likely come through family relationships and membership in CCP subsidiary organizations.

As of 2023, the CCP had 99.19 million members—about 7 percent of China’s population. Among college-educated Chinese likely to study abroad, it’s fair to assume that familial party membership rates are higher. If we assume that the well-connected children of CCP members are two to three times as likely to be represented in this group, around 15 percent to 20 percent could have a parent who is a CCP member. This suggests that about 40,000 to 55,000 current Chinese students could face scrutiny based solely on parental affiliations with the CCP.

Affiliation with subsidiary groups will also ensnare a wide group of students, though it’s worth noting that CCP affiliation does not necessarily indicate ideological commitment. Students at elite Chinese schools typically follow an almost automatic progression through party-affiliated organizations: joining the Young Pioneers in elementary school, advancing to the Communist Youth League in secondary school and university, and eventually joining the CCP itself. This pathway is often viewed as a standard credential for career advancement rather than an ideological statement, particularly among educated professionals.

Meanwhile, the U.S. State Department’s critical fields criteria is intentionally ambiguous and could be drawn from several overlapping frameworks. For example, the White House’s National Science and Technology Council identifies 18 critical technology areas, from artificial intelligence to outer space. However, the list that currently regulates restricted fields of study is the older Technology Alert List, which contains 15 categories, including some surprises such as specific kinds of urban planning.

Under a narrow interpretation limited to reasonably possible military applications—including nuclear engineering, missile design, and cryptography—between several hundred to 2,000 Chinese graduate students could face restrictions. This is assuming that previous estimates from recent years have shrunk as Proclamation 10043 has removed students with military-civil fusion ties, Chinese enrollment has declined, and students have likely self-selected away from sensitive fields, though precise numbers are impossible to determine without more specific enrollment data. Such an interpretation would primarily affect graduate students at major research universities in specific programs with clear defense applications. This deviates from the institutional bans under Proclamation 10043, under which students were denied visas based on ties to Chinese civilian-military universities regardless of whether they studied in sensitive fields.

Expansion of criteria to all 18 critical technologies could be used to encompass virtually all STEM fields and would have an even wider effect. An estimate from the 2018-2019 academic year found that about 32 percent of Chinese undergraduates and 59 percent of Chinese graduate students are in STEM fields. Applied to 2023-2024 enrollment numbers, this expansion would likely affect more than 100,000 students from Hong Kong and China, or 35.6 percent of that total international student population, assuming STEM enrollment rates have not significantly changed and that students from Hong Kong have similar proportions.

The broadest reading—any field with potential dual-use applications that could have military as well as civilian functions—could have a larger but unknowable scope. If urban planning can make the list of critical fields because cities need defense, and since biotechnology includes everything from weapons to medicine, virtually any technical field would become suspect under this interpretation. Combined with the CCP affiliation criteria, this means that few students would be totally safe from having their visas revoked.

However, if the State Department wanted to revoke visas at a more dramatic pace, it has the capability to accelerate. The U.S. Department of Homeland Security’s SEVIS database tracks F-1 visa holders (academic students) and J-1 visa holders (exchange visitors, including students, researchers, and scholars) with real-time updates recorded by their schools. A single algorithm adjustment to capture specific fields, such as employment in certain sectors, could flag thousands overnight.

Before Rubio’s announcement, federal courts in seven states including Massachusetts, Montana, and Wisconsin had issued temporary restraining orders protecting international students from removal. These legal challenges may slow the implementation of the new revocation effort, but they are unlikely to provide much protection to students in the long term. The U.S. Supreme Court’s 2024 Muñoz decision reinforced the executive branch’s broad discretion on immigration matters. The “facially legitimate and bona fide reason” standard, established in 1972, means that the government needs only minimal justification to revoke visas.

In the next few months, revocations will likely continue at the current pace while legal challenges proceed. But by the start of the next academic year, pressure from Trump to demonstrate toughness on China could lead the State Department to expand its efforts.

The maximum scope of this policy would combine the two overlapping criteria of family ties to the CCP, affecting an estimated 40,000 to 55,000 students based on affiliations, and broad interpretation of critical fields, potentially encompassing more than 100,000 STEM students. Accounting for overlap between these categories and keeping in mind that about 47 percent of Chinese and Hong Kong students are likely in STEM, the combined impact would affect a majority of Chinese and Hong Kong graduates and undergraduates studying in the United States.

However, implementing such sweeping restrictions would require extensive new screening systems, training for consular officers on complex affiliation assessments, and significant expansion of data processing capacity, making immediate implementation unlikely.

This estimate does not account for the chilling effect that this policy will have on Chinese students who are not directly targeted but may opt to study elsewhere rather than risk disruption to their studies in the future. It also does not include the potential impact on students who have graduated and are working on optional practical training, a one-year post-graduation period where students are authorized to work in fields related to their degrees.

Even moderate implementation would have profound implications for university enrollment numbers. But this policy’s impact on innovation will be far greater than raw numbers can show. Many of the students who will be affected are the most advanced researchers in critical fields. The students sent packing will take with them not just tuition dollars but also the United States’ competitive edge in the technologies that will define the next century.