MATCH Act Targets Allied Chip Tool Sales

Congress’s proposed Multilateral Alignment of Technology Controls on Hardware, or MATCH, Act would pressure U.S. allies to move beyond today’s partial semiconductor-equipment controls and align more closely with Washington’s China restrictions.

The bill aims to impose China-wide restrictions on deep-ultraviolet lithography systems and related etching tools, tighten controls on associated services, and require the State and Commerce Departments to identify additional semiconductor chokepoints within 60 days of enactment.

Key provisions of the MATCH Act include:

• Country-Wide Prohibition on “Chokepoint” Chipmaking Equipment: Prohibits the sale of the most essential chipmaking equipment to any destination inside a country of concern.
• Tighter Restrictions on China’s National Champions: Designates as covered facilities all fabs run by ChangXin Memory Technologies (CXMT), Hua Hong, Huawei, Semiconductor Manufacturing International Corp (SMIC), and Yangtze Memory Technologies Corp (YMTC), including all subsidiaries and affiliates. Applies Entity-List-like restrictions on exports, servicing, and technical support to these facilities of all items subject to the Export Administration Regulations.
• Leverage for Diplomatic Negotiations: Supports diplomatic negotiations with deadlines for aligning controls. Includes a National Security Waiver if additional time is required.
• Creates a Level Playing Field:The MATCH Act ensures that controls will apply uniformly to U.S. and allied countries.
• If allies cannot demonstrate progress within the 150-day deadline, the Act directs the Department of Commerce to implement controls unilaterally.

Dutch Targeted

One of the most important allied control systems—the Netherlands’ regime governing ASML tools—still leaves major gaps.   In a recent paper Michelle Nie of the Center for a New American Security argues that Dutch controls, while significant, remain too narrow to prevent China from extracting continued value from Dutch technology. 

Nie contends current Dutch rules still permit substantial sales and servicing, do not impose a China-specific presumption of denial, and leave room for transfers of some subcomponents and know-how that can help sustain or upgrade Chinese fabrication capacity. Nie also argues that continued servicing of installed tools may extend the life of equipment China would otherwise struggle to maintain on its own. 

That critique tracks the structure of the Dutch regime itself. The Netherlands expanded its national authorization requirement for advanced semiconductor manufacturing equipment in September 2024, then tightened it again effective April 1, 2025, bringing additional technologies under license requirements. But the Dutch government has described those measures as national controls applied through an authorization system, not as an outright China-wide ban. 

The congressional case for MATCH rests on the view that such country-neutral licensing systems are no longer enough. In a February 9 bipartisan letter, House Foreign Affairs Committee Chairman Brian Mast and Ranking Member Gregory Meeks called for closer cooperation with allies and partners to restrict China’s access to advanced semiconductor manufacturing equipment.

Reuters later reported that lawmakers were pressing for broader, countrywide restrictions on critical chipmaking tools and tighter limits on servicing equipment already installed in Chinese facilities. 

The Dutch debate gives that argument a concrete target. Nie at CSET contends that ASML’s continued sales and servicing in China show how Beijing can keep drawing on allied technology even after successive rounds of controls, supporting the argument that harmonization must mean more than parallel licensing frameworks.

For MATCH supporters, the lesson is that controls must reach not only the most advanced machines, but also the subcomponents, service relationships, and end-use checks that keep older systems productive. 

You can read the bill text here.