GoKawiilA bipartisan group of U.S. lawmakers introduced the Multilateral Alignment of Technology Controls on Hardware Act, or MATCH Act, in early April, targeting the sale and servicing of advanced chipmaking equipment to China.
The bill, filed as H.R. 8170 in the House and with a companion in the Senate, would impose country-wide prohibitions on exports of DUV lithography systems to China, designate five Chinese semiconductor firms as restricted entities by statute, and give U.S. allies 150 days to adopt equivalent controls before Washington expands the Foreign Direct Product Rule unilaterally.
Still in the committee stage, the bill, which has drawn broad congressional support, has since been amended to remove a blanket ban on cryogenic etch tools, though core proposals remain intact.
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Two mechanisms of restriction
The MATCH Act builds its controls on two independent mechanisms. The first is a country-wide prohibition on exports of specific "chokepoint" manufacturing equipment to any destination in China, regardless of end user. Named in the original Bill were DUV immersion lithography systems and cryogenic etch tools, but a recent amendment dropped the latter entirely, leaving DUV lithography tools as the sole country-wide prohibition.
That covers 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 has no domestic equivalent for volume manufacturing; SMEE’s SSA/800-10W scanner remains unconfirmed in production use.
The second mechanism names 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 extending beyond equipment sales to servicing, spare parts, and technical support for already-installed tools.
While the Bureau of Industry and Security’s Entity List currently restricts SMIC (since 2020), Huawei (since 2019), and YMTC (since 2022), it requires Commerce Department officials to evaluate each subsidiary or affiliate on a case-by-case basis and grants the executive branch discretion to approve licenses. Codifying restrictions against these and other Chinese entities into law would eliminate that discretion, meaning that a subsidiary spun off next year or a joint venture created under a different name would be automatically covered.
U.S. Representative Michael Baumgartner (R-WA), who introduced the Bill, says that the legislation closes loopholes that Chinese firms have been exploiting through front companies and third-country routing.
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