The MATCH Act: US Congress Moves to Force Allies to Cut Off Chip Tool Exports to China

The unilateral approach to semiconductor export controls has a well-documented limitation: it doesn’t work as well when allies keep selling. That gap has been a persistent frustration for US policymakers trying to limit China’s access to the most advanced chipmaking equipment, and on April 2, 2026, a bipartisan group of lawmakers introduced legislation designed to close it.

The Multilateral Alignment of Technology Controls on Hardware Act — the MATCH Act — represents the most assertive attempt yet by Congress to extend US technology export restrictions beyond US borders, using the threat of extraterritorial jurisdiction to compel allied nations to align their own export control regimes with Washington’s.

The Gap the Bill Addresses

To understand the MATCH Act, you need to understand deep ultraviolet lithography. When the US successfully pressured the Netherlands to restrict ASML — the world’s sole manufacturer of extreme ultraviolet lithography (EUV) machines — from exporting to China, it was a significant blow to China’s semiconductor ambitions. EUV is required to manufacture chips below roughly 7 nanometers at meaningful scale.

But DUV machines, which use an older, less precise form of lithography, can still produce chips at 7nm and above. And ASML makes those too — as do Japanese equipment makers including Tokyo Electron and Nikon. Despite various restrictions applied since 2022, DUV equipment has continued flowing to China, allowing companies like Huawei and SMIC to push manufacturing capabilities further than the EUV restrictions alone would permit.

SMIC, China’s largest domestic chipmaker, has reportedly achieved limited production of chips using approaches that approximate 5-7nm density through aggressive multi-patterning techniques — using DUV machines to achieve results that would normally require EUV. This is technically difficult, yields are reportedly low, and the approach is economically inefficient compared to frontier EUV manufacturing. But it works well enough to matter for Huawei’s HiSilicon chip designs and China’s domestic AI accelerator programs.

The MATCH Act is designed to close this DUV loophole.

What the Bill Does

The legislation, introduced in the House by Rep. Michael Baumgartner (R-WA) and cosponsored by Select Committee on China Chair John Moolenaar (R-MI), establishes a framework for allied coordination on semiconductor equipment export controls. A companion bill is expected in the Senate, sponsored by Pete Ricketts (R-NE) and Andy Kim (D-NJ).

The bill’s mechanism works in two stages. First, it requires the President to enter into negotiations with key allied governments — primarily the Netherlands, Japan, South Korea, and Taiwan — to establish mutual export control standards for semiconductor manufacturing equipment sold to China, with a focus on DUV lithography tools.

Second, and more controversially, the bill includes an extraterritoriality provision: if allies fail to align their controls within a defined timeframe (reported to be 18 months), the US can invoke jurisdiction over foreign-made equipment that incorporates US-origin technology — essentially applying US export law to ASML’s DUV machines even though they are manufactured in the Netherlands, because they contain components and processes with US origin.

This extraterritorial mechanism is the teeth of the bill. It’s also its most diplomatically sensitive element.

The Allied Response Problem

The Netherlands and Japan have both made partial moves to restrict semiconductor equipment exports to China under diplomatic pressure from Washington. But they have done so cautiously, balancing US requests against the economic interests of their domestic equipment manufacturers and the diplomatic relationships they maintain with Beijing.

ASML, which generates a meaningful portion of its revenue from Chinese customers for DUV systems, has been caught in the middle of this tension for years. The Dutch government restricted the most advanced DUV systems (TWINSCAN NXT:2000i and above) from export to China in 2023, but earlier-generation systems have continued to flow. Tokyo Electron has faced similar constraints.

The MATCH Act’s extraterritoriality provision changes the calculus for both governments. If the US can invoke jurisdiction over equipment made in the Netherlands or Japan because of US-origin components, the legal and business risk for ASML and Tokyo Electron — and by extension for the governments that oversee them — increases dramatically. The threat of being cut off from the US market, or of facing penalties for equipment already in China, is a powerful lever.

European and Japanese government officials have privately pushed back against this approach for years, arguing that it violates WTO principles, undermines allied trust, and creates precedents that could be used against their own exports in other sectors. The MATCH Act makes that abstract argument concrete.

The Huawei and SMIC Calculus

The bill specifically names Huawei and SMIC as the targets its proponents are most concerned about. Both companies have demonstrated a persistent ability to find workarounds to existing export restrictions — Huawei’s Kirin 9000S chip, manufactured by SMIC using DUV-based multi-patterning, became a symbol of the limits of unilateral controls when it appeared in the Mate 60 Pro in 2023 and subsequent devices.

Since then, SMIC and Huawei have continued to push the boundary of what’s achievable with DUV equipment, reportedly achieving lower yields but higher chip densities than independent analysts had expected. The MATCH Act reflects a congressional judgment that this progress, left unchecked, will erode the technology advantage that US chip restrictions are designed to preserve.

The timing is also relevant. China’s AI chip programs — including Huawei’s Ascend series, which competes with NVIDIA’s offerings in the Chinese domestic market — have been advancing on the strength of chips that DUV manufacturing enables. With AI competition between the US and China now a declared national priority in Washington, the political appetite for tightening controls has grown considerably.

Legal and Diplomatic Complexity

Legal scholars and trade policy experts have raised significant questions about the MATCH Act’s extraterritoriality provision. Using US law to regulate equipment manufactured entirely abroad — even if components have US-origin — pushes the limits of established international trade law and risks reciprocal measures from affected countries.

The EU has already signaled that the bloc would treat any application of US extraterritorial jurisdiction to European manufacturers as a serious trade law violation. Japan, whose government has been more accommodating to US requests on semiconductor controls, would nonetheless face significant domestic political pressure if its equipment makers were subject to unilateral US enforcement actions.

There is also a practical question: enforcement. The US has limited ability to directly regulate what happens inside Dutch or Japanese factories, and applying penalties after the fact — through sanctions on the companies or on Chinese end-users — is a blunt instrument that may cause more diplomatic damage than technological gain.

What the bill almost certainly will accomplish, even if the extraterritoriality provision is never invoked, is accelerating multilateral negotiations on DUV controls. The credible threat of US extraterritorial action gives European and Japanese governments the domestic political cover to move more aggressively on their own — allowing them to point to Washington’s legislation as the forcing function rather than accepting the burden of constraining their own companies voluntarily.

In that sense, the MATCH Act may be more valuable as diplomatic leverage than as legislation. Whether it becomes law, or serves primarily as a negotiating instrument, the message to Beijing is the same: the loopholes in the semiconductor export control regime are getting smaller.