Congress moves to strip the DoC of chip-export discretion with the MATCH Act — DUV lithography machines among those targeted in chipmaking tool crackdown

At a glance:

• The MATCH Act targets DUV lithography systems exports to China, specifically ASML's NXT:2000i-class scanners and Nikon's NSR-S631E
• Five Chinese semiconductor firms (SMIC, CXMT, YMTC, Hua Hong, and Huawei) would be designated as restricted entities by statute
• The bill gives U.S. allies 150 days to adopt equivalent controls before Washington expands the Foreign Direct Product Rule

What is the MATCH Act?

The MATCH Act, officially known as the Multilateral Alignment of Technology Controls on Hardware Act, represents a significant bipartisan effort to restrict advanced semiconductor technology exports to China. Introduced in early April as H.R. 8170 in the House with a companion bill in the Senate, this legislation aims to close perceived loopholes in existing export controls by imposing country-wide prohibitions and codifying restrictions directly into law. The bill targets critical chipmaking equipment that China relies on for advanced semiconductor production, particularly DUV lithography systems essential for 7nm manufacturing processes.

The legislation builds on existing export controls but represents a shift from administrative rulemaking to statutory mandates. Unlike current regulations implemented by the Bureau of Industry and Security (BIS) under the Export Control Reform Act of 2018, which can be modified by executive discretion, the MATCH Act would lock certain restrictions into law. This congressional action comes amid escalating technological competition between the United States and China, with both nations vying for dominance in semiconductor manufacturing capabilities that underpin modern computing, artificial intelligence, and military applications.

How does the MATCH Act work?

The MATCH Act establishes two distinct mechanisms for restricting technology transfers to China. The first mechanism imposes a country-wide prohibition on exports of specific "chokepoint" manufacturing equipment to any destination in China, regardless of end user. While the original bill named both DUV immersion lithography systems and cryogenic etch tools, a recent amendment removed the latter, leaving DUV lithography tools as the sole country-wide prohibition. This specifically targets ASML's NXT:2000i-class scanners and Nikon's NSR-S631E, which are widely used by Chinese chipmaker SMIC in its 7nm production lines. China currently lacks domestic equivalents for volume manufacturing at this scale, with domestic firm SMEE's SSA/800-10W scanner remaining unconfirmed in production use.

The second mechanism designates five Chinese companies directly in statute: SMIC, CXMT, YMTC, Hua Hong, and Huawei. All of their fabs, facilities, subsidiaries, and affiliates would be classified as "Covered Facilities" and subject to a presumption-of-denial licensing regime. This restriction extends beyond equipment sales to encompass servicing, spare parts, and technical support for already-installed tools. While the BIS Entity List currently restricts SMIC (since 2020), Huawei (since 2019), and YMTC (since 2022), it requires case-by-case evaluation of subsidiaries and allows executive discretion for license approvals. Codifying these restrictions into law would eliminate that discretion, automatically covering any future subsidiaries or joint ventures created under different names.

Who supports the MATCH Act?

The MATCH Act has garnered bipartisan support in both chambers of Congress. In the House, Representative Michael Baumgartner (R-WA) introduced the bill, with co-sponsors including Chairman of the House Select Committee on Strategic Competition between the United States and the Chinese Communist Party, Representative John Moolenaar (R-MI), and Democrats Jared Golden (D-ME), John Mannion (D-NY), Josh Riley (D-NY), Maggie Goodlander (D-NH), and Suhas Subramanyam (D-VA). In the Senate, Foreign Relations Chairman Jim Risch (R-ID), Senator Pete Ricketts (R-NE), and Senator Andy Kim (D-NJ) introduced the companion bill, with Democratic Leader Chuck Schumer joining as a co-sponsor.

The sponsors emphasize that the legislation closes loopholes that Chinese firms have allegedly exploited through front companies and third-country routing. Representative Baumgartner specifically noted that the bill aims to prevent circumvention of existing controls. The bipartisan nature of the coalition suggests strong political momentum, though the bill's path remains uncertain as it currently sits in House Foreign Affairs and Senate Banking and Foreign Relations committees without scheduled markups. Equipment manufacturers deriving significant revenue from China are expected to lobby against the legislation, potentially creating opposition despite the broad support.

What is the enforcement mechanism?

The MATCH Act's enforcement centers on a multilateral coordination deadline with significant implications for global semiconductor supply chains. Within 60 days of enactment, multiple U.S. departments including Commerce, State, Defense, Treasury, and the Office of the Director of National Intelligence must identify all covered equipment and facilities. Commerce then has 150 days to negotiate equivalent country-wide controls with allied supplier nations, primarily the Netherlands and Japan, which host ASML and Tokyo Electron respectively.

If these negotiations fail, the bill directs Commerce to expand the Foreign Direct Product Rule (FDPR) to cover any foreign-manufactured tool incorporating U.S.-origin software, technology, or components. This would effectively create a near-zero de minimis threshold, as virtually every advanced chipmaking tool relies on some U.S. intellectual property in EDA software, metrology subsystems, or process control algorithms. The Netherlands and Japan, which tightened their own export controls in 2023 and 2024 following U.S. pressure, have not yet commented publicly on the bill but have not adopted restrictions as broad as MATCH proposes. The FDPR expansion represents a particularly contentious element, potentially enabling the U.S. to block sales of entirely foreign-made equipment to non-U.S. customers based on embedded U.S. technology, creating diplomatic friction with allies.

What changes were made to the bill?

Recent revisions to the MATCH Act reflect political considerations and industry feedback. On April 16th, bill sponsors circulated a revised draft that removed two provisions facing significant opposition. The country-wide ban on cryogenic etch equipment, primarily affecting Lam Research and Tokyo Electron, was dropped entirely. Additionally, the automatic presumption of denial on licenses to service equipment installed within Covered Facilities was softened in the revision.

However, these changes are more nuanced than they might initially appear. Existing BIS rules already restrict cryogenic etch tools when destined for advanced-node fabs, defined as sub-16/14nm logic, sub-18nm DRAM, and 128-layer-and-above NAND. The DUV immersion lithography restrictions remained intact in full, as did provisions related to Covered Facilities, the 150-day alignment deadline, and the FDPR expansion authority. The five named Chinese firms also remained in the bill without modification, indicating that the core restrictions targeting China's semiconductor capabilities remain unchanged despite the concessions.

Why does this matter for the semiconductor industry?

The MATCH Act represents a fundamental shift in how U.S. semiconductor export controls are implemented, transferring authority from the executive branch to Congress. Since October 2022, U.S. semiconductor export controls have been administered through BIS rulemakings under the Export Control Reform Act of 2018, allowing administrations to tighten or loosen rules without congressional approval. The MATCH Act would lock specific restrictions into statute, meaning any future relaxation would require an act of Congress.

This change has significant implications for major semiconductor equipment manufacturers. Applied Materials, Lam Research, and KLA collectively booked $19 billion in China revenue in 2025 despite direct U.S.-to-China shipments falling 34%, suggesting that servicing and maintenance constitute substantial portions of their business in China. ASML, which drew approximately 30% of its total 2025 revenue from China, faces particular challenges due to the potential restrictions on servicing scanners already operating in Chinese fabs. While the April revision eased some concerns about maintenance contracts, the FDPR expansion authority could eventually reach tools manufactured at ASML's Veldhoven headquarters if the Netherlands fails to adopt matching controls within the 150-day window.

What happens next?

The future trajectory of the MATCH Act remains uncertain as it navigates the congressional process. The House version (H.R. 8170) currently sits in the House Foreign Affairs Committee, while the Senate version has been referred to Banking and Foreign Relations. No committee has yet scheduled a markup, and the bill faces potential opposition from equipment manufacturers with significant China revenue. Companies deriving 30% or more of their revenue from China are likely to lobby aggressively against the legislation, potentially slowing its progress.

However, the bipartisan coalition behind the bill and current trade tensions between the U.S. and China have created a political environment less hospitable to opposing new restrictions. If enacted, the MATCH Act would represent one of the most significant legislative actions in U.S.-China technology competition, codifying export controls that have previously been implemented through administrative rulemaking. The bill's success could set a precedent for future technology export restrictions and potentially accelerate efforts by China to develop domestic alternatives to foreign semiconductor equipment, reshaping global supply chains for years to come.