MATCH Act to Expand Export Controls to Legacy EUV Equipment

If the MATCH Act (Match Act) under discussion in the U.S. Congress passes, some semiconductor manufacturing equipment currently available to China may become subject to new export restrictions. ASML's Chief Executive Officer (CEO) Christoph Fücke revealed this in a May 2025 interview with TechCrunch, with the equipment assumed to be subject to restrictions being legacy models of DUV (deep ultraviolet) lithography equipment.

DUV equipment is a type of lithography machinery used in the manufacturing process of inscribing semiconductor circuits with light, and ASML has sold it as a flagship product for many years. According to CEO Fücke, what China currently has access to is this legacy-generation DUV equipment, which dates back to products that first began shipping approximately 10 years ago. Since cutting-edge EUV (extreme ultraviolet) equipment used in advanced semiconductor manufacturing is already prohibited from being exported to China, Chinese manufacturers continue semiconductor production by utilizing DUV equipment.

The MATCH Act seeks to extend the scope of restrictions to include these legacy DUV equipment. If the law passes, it would mean further reduction in ASML's sales to China, directly impacting the company's business. ASML is the world's largest semiconductor manufacturing equipment manufacturer based in the Netherlands, and mass production of cutting-edge semiconductors is considered virtually impossible without its products.

In response to these developments, Europe is increasingly vigilant. The expansion of export restriction targets further narrows access to the Chinese market, which European companies have long relied on as a major revenue source in the semiconductor industry. U.S.-led export restrictions were originally strengthened incrementally to prevent the leakage of cutting-edge technology, but the current MATCH Act discussion attempts to extend the scope to legacy equipment, suggesting the logic of regulation is reaching a turning point.

Regarding semiconductor manufacturing equipment export controls, the United States, Netherlands, and Japan have formed a major collaborative framework. However, the content and scope of restrictions are continuously being adjusted between governments and industries of each country, and there are gaps in perception between European companies and U.S. authorities over this legislation. ASML takes the position that legacy equipment is not directly connected to cutting-edge technology development, and discussions on the appropriateness of the regulatory scope continue.

The future focus lies on how the MATCH Act debate is resolved. Whether restrictions 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 policy as a countermeasure to regulatory strengthening is an important variable that will determine the future shape of the international semiconductor supply chain.