China has accumulated 343 deep-ultraviolet (DUV) lithography systems while the U.S. urges allies to close export control loopholes.

Chinese chipmakers, unable to obtain advanced extreme ultraviolet (EUV) equipment, have shifted to bulk purchasing deep ultraviolet (DUV) lithography systems. A new report from the Washington-based Center for Security and Emerging Technology (CSET) estimates that by early 2026, Chinese fabs had cumulatively acquired 343 DUV systems. Former U.S. export control officials are citing these findings to argue that the United States and the Netherlands should impose comprehensive restrictions on the export of related equipment, components, and after-sales services to China.

The analysis reveals a gap in current Western control measures: the Netherlands has restricted exports of certain high-end DUV equipment, but case-by-case reviews and model-specific differences still allow Chinese companies to continue acquiring tools. While DUV is less advanced than EUV, multi-patterning techniques enable manufacturers to produce 7-nanometer logic chips and the advanced memory required for AI processors. Strategic risk, the report argues, cannot be assessed solely by a tool's original intended use.

The CSET report, released September 26 and co-authored by former U.S. export control official Nicholas Brown and former White House and Commerce Department technology policy advisor Saif Khan, estimates that of the 343 DUV systems acquired, approximately 270 are ASML's Twinscan NXT:1980i, along with 22 NXT:2050i units, 6 NXT:2100i units, and 45 lower-tier DUV systems.

Chinese companies spent more than $13 billion on NXT:1980i purchases in 2024, acquiring an additional 89 units in 2025. This purchasing surge is evident in ASML's revenue mix: China accounted for 41% of the company's net sales in 2024 and 33% in 2025.

Since China cannot legally import ASML's most advanced EUV equipment, chipmakers have pivoted toward DUV models that have not yet been fully restricted. The report contends that these tools can be modified and used with multi-patterning processes to support advanced chip production and potentially manufacture components for AI accelerators.

Since September 2023, the Dutch government has required ASML to obtain export licenses for NXT:2000i and higher-end DUV systems, effectively barring direct shipments of those models to China. Controls were expanded in September 2024 to include the NXT:1980i, though exports can still be approved through case-by-case review. The report's authors argue this regulatory design creates a policy gap: equipment nominally intended for mature-node production can be reconfigured, transferred, or integrated into advanced manufacturing processes.

The authors recommend that the United States and the Netherlands coordinate on a comprehensive ban on DUV exports to China while simultaneously restricting equipment maintenance, parts replacement, and technical support. If allies fail to act swiftly and in concert, the report warns, China's continued acquisition of DUV systems could gradually erode the manufacturing advantage held by the United States and its allies in AI chips.

The report estimates that if China maintains its pace of importing roughly 90 NXT:1980i units per year and overcomes other process bottlenecks, it could build capacity to produce up to 434 million AI chips annually by 2035—chips with performance comparable to Nvidia's H100. Even if China were completely cut off from new equipment imports starting in 2027, existing inventory could support annual production potential of up to 153 million AI accelerators, though these projections depend on breakthroughs in wafers, components, process yields, and other manufacturing elements.

Bipartisan lawmakers in the U.S. Congress introduced the Match Act in April, legislation focused on restricting chipmaking equipment and related services that China cannot easily produce domestically, explicitly covering DUV systems. Several senators renewed calls to advance the bill in September, signaling heightened concern in Washington over China's ability to acquire equipment through third-party channels or individual licenses.

The report also recommends that if the United States cannot secure full Dutch cooperation, it should consider extending export controls to foreign-made systems that incorporate U.S. technology. Only by simultaneously restricting equipment supply, maintenance, and upgrades can the United States reduce China's ability to expand advanced chip capacity using existing tools and ensure that future advanced fabs remain concentrated in the United States and allied countries.

For ASML, the Chinese market remains a significant revenue source, though further export restrictions could compress both equipment and service revenue. For China's chip industry, existing DUV inventory provides a degree of buffer but cannot by itself resolve challenges in materials, process control, and mass-production yields. The dispute has shifted from whether to restrict EUV to how to define which DUV equipment can be modified and deployed in advanced manufacturing processes.