A bipartisan group of U.S. senators has proposed a new law that would impose an almost blanked ban on exports of advanced wafer fabrication equipment (WFE) to select entities in adversary nations, a rule that would complement the existing fab-based bans. If imposed, leading China-based chipmakers like CXMT, Hua Hong, SMIC, and YMTC would lose the ability to procure advanced tools for outdated fabs and use them to advance their leading-edge facilities.
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The U.S. government restricted sales of advanced wafer fabrication equipment to potential foes like China back in late 2021. Under these restrictions American companies and eventually companies from allied nations, including the Netherlands and Japan, must obtain an export license from the U.S. government to ship WFE capable of 14nm process technologies for logic, 18nm-class DRAM fabrication processes, and 128-layer or more NAND if they ship to China-based entities. The new proposal does not introduce anything new in terms of curbs. What it does is change how shipments of tools are permitted.
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Today export controls regulate shipments to exact fabs that may or may not be blacklisted by the U.S. government, not entities that own these fabs. To that end, WFE makers can ship advanced machines, such as the ASML Twinscan NXT:1950i/1980Di (which can be upgraded to the sanctioned 5nm-capable NXT:2000i) to companies like SMIC as long as the latter does not use these tools for advanced process technologies. However, controlling how these tools are used is extremely complicated as Chinese chipmakers and authorities do not really endorse such audits. Meanwhile, these advanced tools are indeed used to make chips using 7nm-class process technologies, such as SMIC’s N+1 and N+2.
The newly proposed MATCH Act shifts export controls from fab-based controls to a hybrid model that is company-based (and affiliation-based), though fab-level triggers will remain in place. As a result, companies like SMIC will not be able to buy advanced tools for fabs that use trailing nodes and then redirect them to their fabs capable of 7nm-class technologies.
In addition, the MATCH Act is designed to force global alignment on semiconductor equipment export controls. At first, the U.S. will pursue coordination with allied supplier countries such as the Netherlands, Japan, South Korea, and Taiwan. If that effort fails, then the U.S. will expand restrictions extraterritorially to cover foreign-made tools that contain more than 0% of American technology, or require servicing that relies on American technologies. The end goal is to close loopholes that enable adversaries to circumvent existing controls.
An avid reader who has been following U.S. restrictions on advanced fab tools will ask whether it will be possible for restricted China-based entities to get sophisticated WFE from various intermediaries that are not restricted. As far as we can tell, while intermediary entities can in theory acquire semiconductor manufacturing equipment and divert it illegally, the MATCH Act is explicitly structured to prevent circumvention via intermediaries as export controls attach not only to the initial transaction, but also to end-use, end-user, reexport, and servicing. Therefore, routing semiconductor equipment through a third-party entity would not bypass restrictions, but will instead expose all parties involved, which essentially means losing access to advanced WFE in the future and servicing of existing tools, which in turn will render these machines useless over time.
While the bill cannot eliminate small-scale leakage of advanced systems, one-off tool diversion, or black market activity, it is designed to eliminate reliable supply chains currently used by Chinese entities to get advanced fabrication equipment to build up and maintain world-class fabs.
Last but not least, the MATCH Act introduces the 75% threshold that serves as a built-in calibration mechanism that limits controls to genuine technological chokepoints that countries of concern (i.e., China) cannot produce themselves. For example, if China can meet 75% of its demand for certain tools (e.g., etching or deposition tools), then the U.S. government no longer restricts shipments of appropriate tools to China. Under the newly proposed bill, restrictions are applied where they retain strategic leverage and can be relaxed if domestic alternatives reach sufficient scale. This seems to be important for American companies that sell etching and deposition tools. For now, they maintain lead over Chinese makers like AMEC or Naura, but the latter already offers world-class tools, so once they reach scale, American companies like Applied Materials will lose strategic positions on the Chinese market, at which point the U.S. government will cease regulating their shipments to customers in the PRC.
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