The equipment chokehold: ASML, the MATCH Act, and the end of the allied exemption
A Dutch company in Veldhoven has become the most important instrument of American economic statecraft — and the free market that built it has nothing to do with what happens next.
On 22 April 2026, the House Foreign Affairs Committee advanced by a substantial bipartisan margin a bill that gives the Netherlands 150 days to match American export controls on semiconductor equipment — or lose access to the American intellectual property inside every lithography machine ASML has ever built.[1]
The bill is the Multilateral Alignment of Technology Controls on Hardware Act. The MATCH Act. H.R. 8170, 119th Congress, introduced on 2 April by Representative Michael Baumgartner of Washington State, with a Senate companion — S. 4281 — sponsored by Senators Pete Ricketts and Andy Kim and co-sponsored by Senate Majority Leader Chuck Schumer and the Chairman of the Senate Foreign Relations Committee, Jim Risch.[2] Bipartisan. Bicameral. Committee leadership on both sides of the aisle. This is not a messaging bill sitting on a shelf. This is the formal codification of a structural shift in how Washington treats its allies.
In Part 1 of this series, I described the Hormuz blockade as the moment the post-war bargain inverted — the moment the arrangement that once underwrote European security began pricing European prosperity instead. In Part 2, I argued that you cannot procure sovereignty on imported metal — that the aluminium and helium chokepoints exposed a physical substrate that European digital sovereignty has never costed. Part 3 is different. Parts 1 and 2 were about preconditions Washington cannot control — the chemistry of aluminium, the geology of helium. Part 3 is about the precondition Washington is now attempting to weaponise. The equipment. The machines. The single company in Veldhoven that makes the tools without which no advanced semiconductor can be fabricated anywhere on earth.
The argument I want to make in this piece has two halves.
The first is structural: the allied exemption — the diplomatic consensus that allowed European technology companies to trade with relative autonomy inside a multilateral framework — is formally dead.
The second is political: the instrument Washington has chosen to kill it reveals something uncomfortable about the stated justification for the entire technology embargo. And the two halves connect in the board paper Sarah is writing this week, because the practical consequence for every UK and European organisation is the same: the technology supply chain your procurement function relies on now runs through a jurisdiction you do not control, under rules you did not set, on a timeline you cannot negotiate.
What the MATCH Act actually says
The legislation is precise, and the precision is the point. The MATCH Act establishes a country-wide prohibition on the sale and servicing of what it calls “chokepoint” semiconductor manufacturing equipment to fabrication plants inside China.[1] The covered facilities are named: ChangXin Memory Technologies, Hua Hong, Huawei, Semiconductor Manufacturing International Corporation, Yangtze Memory Technologies Corporation, and all their subsidiaries and affiliates. The prohibited equipment categories include deep ultraviolet immersion lithography and cryogenic etch tools — the two classes of machine that China cannot manufacture domestically and without which advanced-node chip production is physically impossible.
For allied vendors, the mechanism is the 150-day compliance clock. The Netherlands and Japan must align their domestic export restrictions with American rules within 150 days of enactment. In operational terms, “matching” means that allied vendors must cease selling restricted hardware to Chinese fabs and — this is the part that boards need to read twice — halt all technical support, software updates, and maintenance servicing for machines already installed in China.
The consequences at day 151 are not ambiguous. If an allied government cannot demonstrate satisfactory alignment within the window, the Act directs the Department of Commerce to expand U.S. jurisdiction over foreign-produced items containing U.S.-origin software, technology, or components via the Foreign Direct Product Rule.[1] For ASML, that means losing access to the American intellectual property embedded in every machine the company manufactures. Not a tariff. Not a fine. The functional equivalent of a kill switch on the company’s global manufacturing capability.
The silence that tells you everything
Before I go further, I want to name a data point that did not appear in any headline and is, in my analytical judgement, the most important signal in the entire MATCH Act debate.
The Semiconductor Industry Association has not issued a public statement opposing the MATCH Act. Neither has SEMI. Neither has Lam Research. Neither has Applied Materials.[3]
That silence is not diplomatic restraint. It is strategic self-interest. American equipment manufacturers — Lam Research, Applied Materials, KLA — are already barred from selling advanced semiconductor equipment to China under existing Bureau of Industry and Security restrictions. Lam reported that China accounted for more than a third of its Q1 fiscal 2026 revenue, but expects that share to fall below 30 per cent as domestic restrictions tighten.[4] Applied Materials paid a historic $252 million BIS penalty for routing restricted ion implanters to a Chinese entity through a South Korean subsidiary.[5] These companies have already absorbed the commercial damage of the embargo. What they have watched, with increasing frustration, is their European and Japanese competitors continuing to sell into the market they were forced to leave.
The MATCH Act does not restrict American companies. It coerces allied companies into sharing the financial burden of a policy that American companies have already been made to bear. From Lam Research’s perspective, the MATCH Act is not an export control — it is a competitive equaliser. And that is why the American semiconductor industry has not lobbied against it.
The strategic implication is total. There is no cross-Atlantic corporate solidarity on this issue. ASML is alone. The industry association that might have argued against overreach has concluded that the overreach serves its commercial interests. European boards looking for American allies in this fight will not find them.
The honest acknowledgement I owe the security argument
I want to be fair to Washington, because the security argument is not fabricated.
China is building a state-subsidised semiconductor industry with explicit military applications. SMIC has demonstrated the ability to produce 7-nanometre chips using older DUV lithography — a technical achievement that Western intelligence assessments did not expect for several more years.[6] The People’s Liberation Army’s modernisation programme depends on access to advanced computing hardware. The dual-use nature of semiconductor technology means that every advanced chip sold to a Chinese entity is, in a non-trivial sense, a chip that might end up in a weapons system. The security concern is real. The people who drafted the MATCH Act are not stupid, and they are not acting in bad faith on the security question.
But.
The MATCH Act reveals two things about the American position that the security justification does not cover.
The first is the implicit moral claim. The legislation operates on the assumption that American military use of advanced semiconductors is legitimate while Chinese military use is not — and that allied vendors must accept this distinction as the organising principle of their commercial freedom. Whether or not you agree with that distinction — and there are reasonable arguments on both sides of it — the MATCH Act does not ask allied governments to agree. It tells them. Within 150 days. Under penalty of having their most valuable corporate assets functionally disabled. The moral asymmetry may be defensible; the coercive mechanism is not a moral argument. It is a power instrument.
The second is the free market contradiction. The United States has spent the better part of three decades arguing — to Europe, to the World Trade Organisation, to every emerging economy it has negotiated with — that open markets, free trade, and the uninhibited movement of technology are the conditions under which prosperity is maximised. The MATCH Act is the formal legislative admission that Washington no longer believes this. The bill does not restrict trade with an adversary for security reasons while preserving free trade everywhere else. It restricts the free trade of allied companies in allied countries, in markets where those companies have operated lawfully, using technology they developed with their own capital, on a timeline set unilaterally by a government that has no jurisdiction over them except through the supply chain dependencies it is now exploiting.
The argument I want to make here — and I want to label it as my analytical position — is that the MATCH Act is not primarily a security instrument. It is a commercial protection instrument dressed in security language. The security rationale is genuine but partial. The commercial rationale — equalising the competitive damage across allied and American vendors — is the structural driver. And the mechanism chosen to deliver both — extraterritorial coercion of sovereign allies — is the part that European policy has not yet reckoned with honestly.
A company in Veldhoven that has no substitute
The reason the MATCH Act is pointed at the Netherlands before anywhere else is a single company. ASML. Headquartered in Veldhoven, population 45,000, in the province of North Brabant.
ASML holds a 100 per cent monopoly on extreme ultraviolet lithography — the process required to manufacture every advanced logic and memory chip currently in production. Beyond EUV, the company holds approximately 90 per cent of the broader global lithography market, including the older DUV systems that are the specific target of the MATCH Act’s restrictions.[7] In 2025, ASML shipped 535 systems — 48 EUV and 279 DUV — generating record net sales of €32.7 billion, a gross margin of 52.8 per cent, and net income of €9.6 billion.[8]
The numbers matter because they communicate something no adjective can: there is no second source. There is no alternative supplier. There is no European competitor, no Japanese competitor, no Chinese competitor capable of producing EUV lithography at any price on any timeline currently visible. When I argue, later in this piece, that Sarah’s board paper cannot recommend dual-sourcing for the most critical semiconductor equipment, this is why. The equipment layer has a monopoly at its centre, and the MATCH Act converts that monopoly into an instrument of American foreign policy.
China was ASML’s largest single geographic market in 2025, accounting for 33 per cent of total annual revenue, driven by Chinese fabs pulling forward DUV orders ahead of anticipated restrictions.[8] By Q1 2026, China’s share had dropped to 19 per cent as the orders dried up, with South Korea surging to 45 per cent as allied fabs absorbed capacity.[9] ASML projects China will stabilise at approximately 20 per cent of revenue from here, almost entirely from older DUV systems and the installed base management business — the servicing and maintenance contracts that generated €2.5 billion in Q1 2026 alone.
The MATCH Act explicitly targets that remaining baseline. By prohibiting not just the sale of new equipment but the servicing of machines already installed in Chinese fabs, the legislation threatens to drive ASML’s China revenue toward zero. The installed base business is high-margin, recurring, and durable. Its loss would compress ASML’s profitability materially — which is why the company’s gross margin guidance for Q2 2026 has already narrowed to 51–52 per cent under export control uncertainty.[9]
How Washington holds the key: Cymer and the FDPR
ASML is a European company. Its optics come from Carl Zeiss SMT in Germany — Zeiss supplies the hyper-precise lithography optics for EUV systems, with 80 per cent of all microchips produced worldwide running through Zeiss optics via ASML hardware.[10] ASML holds a 24.9 per cent ownership stake in Zeiss SMT, formalised in a strategic partnership dating to 1997. The mechanical and stage systems are European. The company’s 1,600 suppliers in the Netherlands and 700 across the rest of EMEA represent the largest geographic concentration in its supply chain.[8]
None of this European heritage offers any protection against the MATCH Act, because of one acquisition and one legal doctrine.
The acquisition is Cymer. Based in San Diego, Cymer provides the light source technology for ASML’s EUV systems — the laser-produced plasma source without which the physics of extreme ultraviolet lithography do not function.[^11] ASML acquired Cymer, making the American intellectual property integral to every EUV machine the company builds. The light source is not a component that can be substituted or sourced elsewhere. It is the enabling technology. Without Cymer’s IP, the optics from Zeiss have nothing to focus, and the most advanced lithography system on earth becomes an extraordinarily expensive piece of inert precision engineering.
The legal doctrine is the Foreign Direct Product Rule. The FDPR allows the United States to claim jurisdiction over items produced entirely outside the U.S. if those items are the direct product of U.S.-origin technology or software.[12] Under the December 2024 expansion of export controls, BIS broadened the rule to cover foreign-produced semiconductor manufacturing equipment containing “any amount of U.S.-origin integrated circuits” — and, more profoundly, declared that any integrated circuit manufactured anywhere in the world using U.S. machines is legally classified as U.S.-origin.[13] The practical reach of this doctrine is nearly total. Washington does not need to deploy a naval blockade or impose tariffs. It needs only to threaten the revocation of licences that permit ASML to use Cymer’s technology. The coercive surface area extends through Cymer into Zeiss, into the German industrial base, and into the entire European semiconductor equipment supply chain.
ASML’s 2025 Annual Report discloses 5,100 total suppliers globally, of which 1,350 are in North America.[8] That is 26 per cent of the company’s supplier base sitting inside U.S. jurisdiction. The tethering is physical, legal, and structural.
The death of consensus: from Wassenaar to the 150-day clock
Since the end of the Cold War, export controls among allied nations have been coordinated through the Wassenaar Arrangement — a consensus-based regime in which member states collaboratively identify dual-use goods and technologies requiring restriction, with each government retaining sovereign authority over its own trade policy and enforcement.[14] The model is deliberative, slow, and respectful of national sovereignty. It is also, from Washington’s perspective, structurally incapable of keeping pace with the speed at which China’s state-subsidised semiconductor industry is closing capability gaps.
The MATCH Act bypasses Wassenaar. It replaces multilateral consensus with a unilateral deadline. The 150-day clock does not ask the Netherlands to join a new regulatory regime. It tells the Netherlands to adopt American domestic policy within five months, or face the dismantling of ASML’s manufacturing capability via the FDPR. Altering national trade law in the Netherlands requires parliamentary process, regulatory consultation, and compliance infrastructure — none of which can be artificially compressed by a foreign legislature’s timetable.
There is no modern precedent for this. The closest analogy is the 1987 Toshiba-COCOM incident, in which Congress sanctioned Toshiba Machine Company for selling restricted submarine-milling equipment to the Soviet Union.[15] But that was a punitive, reactive measure against a specific corporate entity for violating an existing, jointly agreed set of rules. The MATCH Act is structurally different. It is a proactive mandate directed at allied sovereign governments, demanding the adoption of American policy within a fixed deadline, under threat of consequences that the allied government’s own legal framework has no mechanism to counter.
A correction I owe the series
In Part 1, I cited a 19 per cent reduction in Bureau of Industry and Security headcount and an average export licence processing time for allied nations of 76 days, double the 2023 baseline. I owe the reader a correction. The 19 per cent figure is wrong. Congress actually increased the BIS budget by 23 per cent — approximately $44 million — for 2026, earmarking the funds for additional enforcement personnel to police semiconductor controls.[16] The “76” is not days but a percentage: a CSIS survey found that 76 per cent of technology exporters reported that more than $10 million in exports were delayed by pending BIS reviews.[17]
The correction matters because the underlying reality is worse than the numbers I originally cited. The official BIS average processing time is 38 days.[18] But the CSIS survey — the most comprehensive independent assessment of export licence friction — found that 56 per cent of respondents reported average review times exceeding 180 days, and 33 per cent reported waiting over 300 days.[17] More than half of surveyed exporters reported losing business or contracts to foreign competitors not subject to U.S. regulatory jurisdiction. The bottleneck is not a staffing problem. It is a cultural transformation: BIS has shifted from trade facilitation to enforcement policing, with 200 new Export Enforcement Special Agents funded by the 2026 budget increase, and Under Secretary Jeffrey Kessler facing congressional accusations of being too lenient on licence approvals.[16]
The practical consequence for a UK or European company in the ASML supply chain is that even full compliance with the MATCH Act’s requirements does not guarantee frictionless access to U.S.-origin technology. The 150-day clock is the legislative mechanism. The 180-to-300-day licence queue is the administrative reality. Both operate on your business simultaneously.
The silence from Brussels
On 14 April 2026, Dutch Prime Minister Rob Jetten visited the White House and pushed back against the proposed U.S. export limits on ASML. The talks involved open disagreement, with both sides recognising each other’s positions without reaching consensus.[19]
From the European Commission: nothing.
No formal condemnation. No threat of countermeasures. No legislative proposal for a European regulatory shield. No organised diplomatic response to a piece of American legislation that explicitly threatens to dictate the operational parameters of Europe’s most valuable technology company under penalty of sanctions that would functionally disable its manufacturing capability.[20]
This silence is not caution. It is structural paralysis. The European Union maintains a single economic market, but member states retain sovereign authority over national security and export control policy. Brussels lacks the centralised regulatory power to enact a unified defence of ASML — or of any European technology company caught in the FDPR’s extraterritorial reach. Washington understands this architecture intimately and has optimised the MATCH Act to exploit it, applying bilateral pressure to the Hague while bypassing the Commission entirely.
The Commission’s silence should not be read as acquiescence. It should be read as incapacity. And that incapacity — the gap between the EU’s economic integration and its geopolitical fragmentation — is the structural vulnerability that Part 4 of this series, on the CLOUD Act and data jurisdiction, will examine in detail. The equipment chokehold and the data jurisdiction are the same problem expressed in different materials: American extraterritorial reach operating on European commercial activity through supply chain dependencies that European governance structures are not configured to counter.
What Sarah’s board paper must now say
In Parts 1 and 2, I gave Sarah — the senior risk director writing a quarterly paper for the Audit and Risk Committee — specific amendments to her vendor concentration matrix, her capital expenditure forecast, and her political risk register. Part 3 adds a harder recommendation. Harder because it is honest about what it cannot solve.
Sarah must audit which of her organisation’s technology vendors depend on supply chains that run through U.S. export control jurisdiction. Not just direct vendors — the tier-two and tier-three dependencies. Any vendor whose equipment, software, or infrastructure contains U.S.-origin intellectual property captured by the FDPR is exposed to the MATCH Act’s enforcement mechanism, whether or not that vendor is American.
For most of the technology stack, Sarah can recommend dual-sourcing. Etch equipment, deposition tools, metrology systems — alternatives exist, even if they are imperfect. Tokyo Electron in Japan holds 87 per cent of the track equipment market and 13.4 per cent of the broader equipment market; its China revenue has already declined from 40.3 per cent to 31.8 per cent under METI’s own export control tightening.[21] Dual-sourcing across ASML and TEL for some process steps is technically feasible if commercially expensive.
For EUV lithography, Sarah cannot dual-source. There is no second supplier. There is no European alternative, no Japanese alternative, no alternative of any kind at any price on any timeline shorter than a decade. The EU’s €700 million investment in the NanoIC semiconductor pilot line at imec in Leuven is a research programme, not a manufacturing alternative.[22] Carl Zeiss SMT supplies optics, not complete lithography systems — and Zeiss itself is tethered to ASML’s architecture and, through ASML, to Cymer’s American IP.
Sarah’s board paper must therefore contain a line it has never contained before: a named, quantified, irreducible single-vendor dependency with no current mitigation. For the EUV layer, the risk is accepted or the capability is forgone. The board must know this, in those terms, before the MATCH Act’s 150-day clock begins to run.
The MATCH Act prediction
Within 12 months — by April 2027 — the European Commission will publish a formal legislative proposal for a Chips Act 2.0 that includes, for the first time, a sovereign equipment supply chain pillar with a dedicated budget line for reducing U.S.-origin IP dependency in European-manufactured semiconductor equipment.[23]
The signals to watch: Commission Staff Working Documents referencing “equipment sovereignty” or “supply chain de-risking” in the semiconductor equipment layer. Internal Market Commissioner statements on ASML’s strategic classification. Horizon Europe or Digital Europe programme calls explicitly targeting lithography component development. And — the clearest signal — any formal communication between the Commission and ASML’s board regarding the company’s classification under the EU Foreign Subsidies Regulation or the Critical Raw Materials Act framework.
The prediction is falsifiable. If by April 2027 no such proposal has been published, and no draft legislation is in inter-service consultation, the prediction is wrong. If the Commission addresses the equipment chokehold through non-legislative means — guidelines, political declarations, bilateral agreements with the Netherlands — that does not satisfy the prediction. The argument here is that the MATCH Act forces a legislative response from Brussels, because the alternative — continued structural paralysis while Washington dictates the terms of European technology companies’ commercial freedom — is not a position the Commission can sustain through another European Council cycle.
The bottom line
Remember the house from Parts 1 and 2? The foundations that nobody paid for — the aluminium, the helium, the metal floor? The foundations are still unpaid. But Part 3 has introduced a new problem. The house has a landlord.
The landlord did not build the house. ASML is Dutch. Zeiss is German. The semiconductor equipment supply chain is overwhelmingly European in engineering, European in manufacturing, and European in intellectual heritage. But the landlord holds one key — the Cymer light source, the American IP — and that key opens every door in the building. The MATCH Act is the landlord’s letter to the tenant: match my rules within 150 days, or I change the locks.
The United States built the most powerful technology industry in human history on the argument that free markets produce better outcomes than state direction. The MATCH Act is the legislative acknowledgement that Washington no longer believes this — at least not when the free market produces outcomes that benefit a competitor. The bill does not restrict an adversary’s access to technology. It restricts an ally’s freedom to sell technology the ally developed, in markets the ally chose, using capital the ally raised. The security justification is real but partial. The commercial equalisation is the structural driver. And the mechanism — extraterritorial coercion of sovereign allied governments via supply chain dependencies — is not a free market instrument. It is the opposite.
You cannot build sovereignty on someone else’s permission.
That sentence is the argument of this piece. Everything else has been evidence. The metal floor from Part 2 is the precondition nobody costed. The equipment chokehold is the precondition somebody else controls. And the question for every UK and European board is no longer theoretical: when the landlord’s letter arrives — when the 150-day clock begins — which of your supply chains run through the building he owns?
Part 4 will follow the landlord inside the house. The CLOUD Act — the legal instrument that gives U.S. law enforcement access to data held by American cloud providers regardless of where that data is physically stored — is the same permission problem applied not to equipment but to information. The metal floor, the equipment chokehold, and the data jurisdiction are three expressions of a single structural condition: European commercial activity operating inside American extraterritorial reach, with no European governance mechanism configured to counter it.
The Control Layer exists to make that condition legible on a quarterly risk paper, in a voice a board will quote. If that is the translation you have been looking for, subscribe — and forward this to the colleague who is about to discover that the allied exemption was always American permission.
Next: Part 4 — The data jurisdiction: the CLOUD Act and the landlord who reads your post.
References
[1]: U.S. House of Representatives. Multilateral Alignment of Technology Controls on Hardware Act, H.R. 8170, 119th Congress (2026). Introduced 2 April 2026. House Foreign Affairs Committee markup, 22 April 2026: advanced 36-8.
[2]: U.S. Senate. Multilateral Alignment of Technology Controls on Hardware Act, S. 4281, 119th Congress (2026). Sponsors: Sen. Pete Ricketts (R-NE), Sen. Andy Kim (D-NJ). Co-sponsors include Senate Majority Leader Chuck Schumer (D-NY) and Sen. Jim Risch (R-ID), Chairman, Senate Foreign Relations Committee.
[3]: Based on an exhaustive review of public statements, press releases, and congressional testimony from the Semiconductor Industry Association (www.semiconductors.org), SEMI , Lam Research, and Applied Materials through April 2026. No formal industry statement opposing H.R. 8170 was identified.
[4]: Lam Research Corporation. Q1 Fiscal Year 2026 Earnings Release. China revenue exceeded one-third of total quarterly revenue; projected decline below 30 per cent under tightening domestic restrictions.
[5]: U.S. Bureau of Industry and Security. Administrative Penalty: Applied Materials, Inc. $252 million civil penalty for illegal export of ion implanters to a Chinese entity via South Korean subsidiary.
[6]: Multiple corroborated industry reports on SMIC’s 7nm process capability using DUV multi-patterning, first reported in 2023 and confirmed in subsequent U.S. intelligence assessments.
[7]: ASML Holding N.V. Annual Report 2025. EUV market share: 100 per cent. Broader lithography market share: approximately 90 per cent. https://www.asml.com/en/investors/annual-report
[8]: ASML Holding N.V. Annual Report 2025. Total net sales: €32.7 billion. Gross margin: 52.8 per cent. Net income: €9.6 billion. Systems shipped: 535 (48 EUV, 279 DUV). Supplier network: 5,100 total (1,600 Netherlands, 1,450 Asia, 1,350 North America, 700 EMEA ex-NL). China revenue: 33 per cent of FY 2025.
[9]: ASML Holding N.V. Q1 2026 Quarterly Earnings Report. Net sales: €8.8 billion. Gross margin: 53.0 per cent. Installed base management revenue: €2.48 billion. China revenue: 19 per cent. South Korea: 45 per cent. Q2 2026 gross margin guidance: 51–52 per cent. China projected to stabilise at approximately 20 per cent.
[10]: Carl Zeiss SMT GmbH. ASML strategic partnership formalised 1997. ASML holds 24.9 per cent ownership stake in Zeiss SMT. Approximately 80 per cent of global microchip production utilises Zeiss optics via ASML lithography hardware.
[11]: Cymer, Inc. (San Diego, CA). Acquired by ASML. Provides laser-produced plasma light source technology for EUV lithography systems. U.S.-origin intellectual property integral to all ASML EUV machines.
[12]: U.S. Bureau of Industry and Security. Foreign Direct Product Rule — Export Administration Regulations, 15 CFR Part 734. Expanded October 2022 and December 2024.
[13]: U.S. Bureau of Industry and Security. December 2024 Semiconductor Export Control Updates. Expanded FDPR jurisdiction to cover foreign-produced SME containing “any amount of U.S.-origin integrated circuits” and classified all ICs manufactured using U.S. equipment as U.S.-origin.
[14]: The Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies. Established 1996. 42 participating states. Consensus-based decision-making on dual-use technology restrictions.
[15]: U.S. Congress. Toshiba-COCOM Sanctions, 1987. Punitive sanctions against Toshiba Machine Company for sale of restricted submarine-milling equipment to the Soviet Union in violation of COCOM rules.
[16]: U.S. Department of Commerce. BIS Budget Allocation FY 2026. 23 per cent increase (approximately $44 million) earmarked for enforcement personnel. 200 new Export Enforcement Special Agents funded. Congressional scrutiny of Under Secretary Jeffrey Kessler regarding licence approval transparency.
[17]: Center for Strategic and International Studies (CSIS). Survey of U.S. Technology Export Licensing Friction, 2025–2026. 56 per cent of respondents reported average review times exceeding 180 days. 33 per cent reported wait times exceeding 300 days. 76 per cent reported more than $10 million in exports delayed by pending reviews. More than 50 per cent reported losing business to foreign competitors.
[18]: U.S. Bureau of Industry and Security. Annual Report, Fiscal Year 2023. Official average export licence processing time: 38 days.
[19]: NL Times. ‘Netherlands pushes back against proposed U.S. export limits on ASML,’ 14 April 2026. Reports that Dutch PM Rob Jetten discussed the MATCH Act during a White House visit and that talks “involved some disagreement, with both sides recognising each other’s positions without reaching consensus.”
[20]: Based on a review of European Commission press releases, EU Trade Commissioner statements, and European Parliament resolutions through April 2026. No formal EU institutional response to H.R. 8170 identified.
[21]: Tokyo Electron Ltd. Fiscal Year 2026 Quarterly Earnings. Track equipment market share: 87 per cent. Overall equipment market share: 13.4 per cent. China revenue: declined from 40.3 per cent (Q2 FY2026) to 31.8 per cent (Q3 FY2026). Japanese Ministry of Economy, Trade and Industry (METI): 23-item export control notice implemented; Japan passed centralised economic security intelligence legislation, April 2026.
[22]: European Union. NanoIC Semiconductor Pilot Line, imec (Leuven). €700 million investment under Chips Act / Horizon Europe framework. Research and development programme; not a commercial manufacturing alternative to ASML lithography.
[23]: Predictive judgement. Not based on any published Commission document. Based on the analytical assessment that the MATCH Act’s extraterritorial reach into European semiconductor equipment supply chains creates a legislative forcing function that the Commission’s current non-response cannot survive through another European Council cycle.
Author
Amer Altaf is Founder and CEO of Arkava, a UK and European sovereign AI agentic automation business, and Managing Editor of The Control Layer, the publication where he tracks the convergence of cyber security, technology sovereignty, and geopolitics. A techUK member, he contributes to industry engagement on UK technology sovereignty policy. He is currently writing on cloud security for Oxford University Press’s Expert Essentials series.