U.S. semiconductor export controls increasingly depend on cooperation with allies that control critical technologies but do not always share identical economic interests. The MATCH Act highlights why durable controls require not just allied compliance, but greater allied ownership in designing them.
In April, the U.S. House Foreign Affairs Committee advanced the bipartisan Multilateral Alignment of Technology Controls on Hardware, or MATCH Act. The legislation addresses a longstanding weakness in U.S. technology policy: restrictions on China’s access to technologies relevant to advanced military, artificial-intelligence, and computing capabilities lose effectiveness when comparable technology remains available from suppliers in allied countries.
But the legislation also exposes a deeper problem. Effective semiconductor restrictions increasingly depend on the Netherlands, Japan, South Korea, and Taiwan, partners that share many U.S. security concerns but have their own economic interests and assessments of risk.
The question is therefore no longer simply whether allies should coordinate export controls. They should. The harder question is who gets to design them.
ASML and the Dutch dilemma
ASML, the Dutch semiconductor-equipment company originally known as Advanced Semiconductor Materials Lithography, occupies an extraordinary position in the global chip industry. It is the world’s only manufacturer of Extreme Ultraviolet (EUV) lithography systems, which are essential to manufacturing the world’s most advanced chips, while its Deep Ultraviolet (DVU) systems remain important across a wider range of production. The Netherlands has progressively tightened its controls since 2023, expanding restrictions on DUV equipment in 2024 and adding certain measuring and inspection technologies in 2025.
The Dutch government has justified its controls on security grounds, including the potential contribution of advanced technology to military applications, while also stressing the importance of open markets and international cooperation.
The economic stakes are substantial. Chinese customers accounted for 29.1 percent of ASML’s total net sales in 2025, down from 36.1 percent in 2024. Decisions over which equipment ASML can sell therefore affect not only allied security but also Dutch economic interests.
The MATCH Act would push this debate further. The legislation seeks greater alignment between U.S. restrictions and those imposed by allied technology-producing countries and creates a mechanism through which Washington could extend controls to certain foreign-produced items when sufficient alignment is not achieved. The Dutch government has formally raised concerns about the MATCH Act and its potential extraterritorial effects, including possible consequences for ASML’s ability to service and maintain equipment already delivered to Chinese customers.
A Problem That Goes Beyond the Netherlands
Japan, another major producer of semiconductor manufacturing equipment, added 23 types of advanced equipment to its export-control regime in 2023, citing military-diversion risks and international security.
South Korea has more direct commercial exposure. Samsung and SK Hynix maintain substantial semiconductor manufacturing capacity in China; according to Taiwan’s Ministry of Economic Affairs, roughly 20 percent of Samsung’s DRAM capacity and 40 percent of SK Hynix’s is located there. Tighter controls can therefore affect not only access to the Chinese market but also Korean-owned factories in China. Taiwan, by contrast, accounts for more than 90 percent of global leading-edge chip manufacturing and has tightened technology controls, adding Huawei and SMIC to its Strategic High-Tech Commodities Export Control Entity List in 2025. It also faces a direct security threat from Beijing, making control over these technologies of particular strategic importance.
The trade-offs involved in tighter controls therefore differ considerably among allies. A system based on allies matching restrictions designed in Washington is likely to encounter resistance. These countries control technologies and production capacity without which the restrictions may not work.
The Limits of Compliance
The logic behind the MATCH Act is understandable: diplomacy alone may not produce sufficient alignment. If an American manufacturer is prohibited from supplying technology to a Chinese company while a Dutch or Japanese competitor can provide an equivalent product, restrictions might shift trade rather than constrain the targeted capability.
There is evidence of this happening. Research by the European Commission’s Joint Research Centre found that U.S. semiconductor export controls reduced targeted U.S. exports to China, while exports of semiconductor manufacturing equipment from the EU, Japan, and Singapore increased significantly.
Compliance asks whether the Netherlands, Japan, South Korea, or Taiwan has moved sufficiently close to a policy developed primarily in Washington. Co-design begins earlier. In the case of China, co-design asks allies to determine together which Chinese capabilities pose an unacceptable security risk, which technologies enable those capabilities, and which controls are most likely to constrain them without imposing unnecessary economic and diplomatic costs.
As controls expand beyond technologies directly linked to cutting-edge military, artificial-intelligence, or advanced-computing capabilities, the security benefits become harder to weigh against the economic costs. Allies therefore need to distinguish focused national-security measures from a wider effort to contain China’s technological development. If that boundary becomes unclear, governments risk weakening support for the restrictions that matter most.
How to Move from Compliance to Co-Design
A stronger allied system should begin with three principles.
First, define capabilities before products. The United States, the Netherlands, Japan, South Korea, Taiwan, and other relevant partners should jointly identify the military and advanced-computing capabilities they intend to constrain before negotiating lists of controlled equipment. Instead of asking whether allies have adopted similar product lists, governments would first agree on which capabilities they want to restrict. Because technology evolves faster than export-control lists, they could then assess which technologies enable those capabilities.
Second, incorporate allied costs into the design of controls.Economic costs do not outweigh national-security concerns, but neither are they irrelevant. If controls require Dutch, Japanese, Korean, or Taiwanese companies to give up access to important markets, their governments should have a say in where those restrictions are drawn. Supporters of the MATCH Act themselves argue that uneven controls put American semiconductor-equipment companies at a competitive disadvantage relative to foreign suppliers. While that concern may be legitimate, it also reinforces the case for co-design. Security measures should not leave allies feeling that commercial advantages are simply being shifted from one country to another.
Third, evaluate controls for effectiveness. Governments should periodically assess whether restrictions have constrained the capabilities they target, how trade and alternative suppliers have responded, whether enforcement remains practical, and whether the security benefits still justify the economic and diplomatic costs.
This would not require a new international organisation. Governments could establish a standing mechanism to assess security risks, technological chokepoints, and economic costs. Each country would retain control over its own export rules, but allies would design common measures together.
Allied Ownership
The Netherlands should not seek equidistance between Washington and Beijing. It is a U.S. ally and recognises the genuine national-security implications of advanced semiconductor technology. But alliance does not require identical interests. No government controls all the technologies and production capacity required to produce the world’s most advanced chips. That interdependence can also be a strategic advantage.
Washington’s ability to restrict China’s access to advanced semiconductor technology is much greater when the countries controlling key chokepoints act together. But that leverage is sustainable only if those countries help shape the policies they are being asked to enforce.
The MATCH Act addresses the problem of asymmetric export controls. But it risks falling short by treating alignment as something to obtain from allies rather than something to design with them. Without that ownership, Washington risks creating controls that become increasingly expansive but progressively harder to sustain as a common allied strategy.
For Washington, the lesson from ASML should therefore extend well beyond the Netherlands to realise effective technology alliances require more than allied compliance. They require allied ownership of the strategy.
Hannah Zhang (hezhang@taftschool.org) is a Dutch student at The Taft School in Connecticut, U.S. Her research interests include international relations, U.S.-China competition, and the strategic choices facing smaller states. Her work has been published by Pacific Forum and Global Policy.
This article is published under a Creative Commons License and may be republished with attribution.
