MATCH Act to Include Legacy EUV Equipment in Export Controls

If the MATCH Act under review in the U.S. Congress becomes law, some of the semiconductor manufacturing equipment that China can currently purchase may be added to new export control measures. According to an interview TechCrunch conducted with Christoph Fouquet, Chief Executive Officer of ASML, in May 2025, the equipment anticipated as a control target is a legacy model of deep ultraviolet (DUV) lithography equipment.

DUV equipment is a type of lithography machinery used in semiconductor manufacturing processes to draw circuits onto silicon wafers using light. It has long been a core product sold by ASML. According to Fouquet, the legacy DUV equipment China can currently obtain corresponds to products that first began shipments approximately ten years ago. Because cutting-edge extreme ultraviolet (EUV) equipment used in advanced semiconductor manufacturing is already banned from export to China, Chinese manufacturers continue semiconductor production using DUV equipment.

The MATCH Act seeks to expand regulatory scope to include these legacy DUV devices. If the law passes, it would mean further reduction in ASML's sales to China, with direct impacts on the company's business operations. ASML is the world's largest semiconductor manufacturing equipment manufacturer headquartered in the Netherlands, and it is widely recognized that producing advanced semiconductors at scale is practically impossible without its products.

In response to these developments, Europe has heightened its vigilance. The expansion of export control targets further narrows European companies' access to the Chinese market, which has been a major revenue source for the semiconductor industry. U.S.-led export controls have been incrementally strengthened with the original aim of preventing the leakage of cutting-edge technology. However, the current MATCH Act discussion extends this scope to legacy equipment, suggesting that the logic of regulation is reaching an inflection point.

Regarding semiconductor manufacturing equipment export controls, the United States, the Netherlands, and Japan have formed a major cooperative framework. However, the content and scope of regulations continue to be adjusted repeatedly between national governments and industry players. There is a perception gap between European companies and U.S. authorities regarding this legislation. ASML maintains that legacy equipment does not directly contribute to advanced technology development, and the debate over the appropriateness of the regulatory scope continues.

The key focus going forward is how the MATCH Act deliberations will be resolved. Whether regulations extend to legacy equipment will significantly impact the business strategies of European semiconductor equipment manufacturers including ASML. Additionally, how far Europe can assert its own trade policies as a countermeasure to regulatory tightening will be an important variable that shapes the future international semiconductor supply chain landscape.