Trade Controls Briefing · Published Jan 15, 2025

ASML export controls tighten

Executive briefing: ASML’s China shipments face layered Dutch and U.S. controls that bar extreme ultraviolet (EUV) systems entirely and now require licenses—and in some cases revocations—for leading deep ultraviolet (DUV) immersion tools.

• Dutch licensing regime. The Netherlands added export license requirements for advanced lithography equipment effective September 1, 2023, covering high-NA immersion systems shipped from January 1, 2024.
• U.S. rule alignment. BIS October 2023 and January 2024 rules extend U.S. jurisdiction to certain DUV tools when configured for advanced logic; ASML confirmed in January 2024 that some NXT:2050i and NXT:2100i licenses for China were revoked.
• Operational impact. Chinese fabs can still receive older ArF systems, but advanced-node ramps face longer lead times and uncertainty as each shipment requires case-by-case authorization.

Risk considerations

• Tool delivery forecasts for Chinese customers should incorporate licensing contingencies and parallel procurement of domestic lithography alternatives.
• Vendors integrating U.S.-controlled components into DUV subsystems must maintain part-level export classifications to avoid downstream violations.
• Non-Chinese fabs should monitor for allocation shifts if ASML reprioritises capacity toward licensed destinations.

Sources

• Government of the Netherlands — Export controls on advanced semiconductor manufacturing equipment (June 30, 2023)
• ASML — Update on U.S. export control regulations (January 2024)
• U.S. BIS — Implementation of Additional Export Controls on Advanced Computing Items (October 17, 2023)

Zeph Tech tracks cross-border lithography controls to flag lead-time and compliance risks.