China’s access to immersion deep-ultraviolet lithography is at the center of an export-control debate after a South China Morning Post account highlighted a Center for Technology & Statecraft estimate of 343 such systems at Chinese-owned fabs by early 2026. That number is consequential precisely because it is not a confirmed census of operating equipment. It is a modeled central estimate of cumulative imports as Washington and allied governments debate whether to tighten controls on older tools.
The distinction matters. The Center for Technology & Statecraft does not present 343 as an audited inventory, a count of machines currently in use, or a measure of current chip output. Its framework excludes imports before 2012 and does not model retirements or re-exports. Still, the estimate places immersion DUV equipment at the center of an argument that restrictions focused only on the newest lithography systems can leave an installed base whose technical relevance persists long after shipments are curtailed.
China’s Immersion-DUV Estimate Is a Cumulative Import Model
The Center for Technology & Statecraft estimates that China imported 396 immersion-DUV, or DUVi, systems from 2012 through the first quarter of 2026. Its central 80% model range runs from 361 to 444 systems. After subtracting estimated imports at four multinational fabs, the analysis estimates a range of 312 to 383 systems for Chinese-owned fabs, with 343 as the central figure. Each of those figures describes modeled cumulative imports, not a verified operational fleet.
The model also gives a more granular view of the equipment it estimates. For Chinese-owned fabs, it estimates 249 to 294 ASML NXT:1980i systems, centered at 270; 22 NXT:2050i systems; six NXT:2100i systems; and 29 to 69 NXT:1970i and less-advanced systems, centered at 45. These estimates should not be read as a machine-by-machine map of any individual fab. They instead illustrate why the policy conversation reaches beyond a single scanner model or a single Chinese chipmaker.
The Center says the NXT:1980i can support 7nm logic and 1y memory production nodes used for Huawei’s Ascend AI chips. That is a capability assessment tied to the report’s view of the tool, rather than evidence of a stated volume of Huawei chip production. The SCMP likewise summarized the assessment as saying some DUV systems can be adapted for 7nm logic and advanced memory. Neither account establishes how many machines are running, what yields they achieve, or how many chips they have produced.
That caution is vital to interpreting the estimate. Lithography capacity depends on the condition, configuration, servicing, process integration, and the rest of a fab’s equipment stack. Cumulative imports do not settle those questions. The estimate does, however, frame the strategic issue: equipment imported before any additional restriction may remain part of China’s manufacturing options even if future deliveries become more difficult.
ASML’s China Sales Show the Commercial Stakes Around Older Tools
The policy issue has a corporate dimension because ASML’s DUV business in China was stronger than it anticipated in 2025, according to the company’s 2025 Annual Report. ASML said stronger-than-anticipated China DUV business offset marginally weaker non-China DUV business. That company disclosure does not independently validate the Center’s equipment estimate or identify the use of any particular tool, but it underscores that DUV demand remained commercially significant.
ASML reported 2025 total net sales of €32.7 billion, up 15.6% year over year. It reported €24.5 billion in net system sales and €8.2 billion in service and field-options sales. Those are companywide results, not a valuation of China’s DUV holdings and not a China-only revenue breakout. For 2026, ASML guided to total net sales of €34 billion to €39 billion and said it expected non-EUV revenue to be similar to 2025. That guidance reflects management’s expectations, not a measure of future Chinese demand.
Reuters reported that China accounted for 33% of ASML sales in 2025 and that ASML said in January it expected the share to fall to 20% in 2026. Reuters’ figures cover ASML sales overall, so they cannot be treated as the China share of DUV alone. Reuters also characterized immersion DUV as technology China relies on to create chip circuitry and identified ASML as the dominant supplier in that segment, with Nikon as a smaller Japanese rival.
The commercial picture helps explain the policy pressure. Existing rules coordinated with the United States and enforced by the Dutch government already block ASML from shipping its most advanced tools to China, Reuters reported. Older DUV lines could still be sold to Chinese chipmakers and to South Korean and Taiwanese companies operating in China, according to Reuters. The debate is therefore over whether the remaining channel for older equipment and related support should be narrowed further, not over a blanket prohibition that has already taken effect.
BIS Rules, the MATCH Act, and a Separate Call for a DUVi Ban
The United States has already built a substantial control architecture. The Bureau of Industry and Security announced on December 2, 2024, controls on 24 types of semiconductor-manufacturing equipment and three types of software tools, along with high-bandwidth-memory controls, 140 Entity List additions, and 14 modifications. BIS said its stated aim was to restrict the People’s Republic of China’s ability to produce advanced-node semiconductors relevant to military applications and AI and advanced computing.
BIS described controlled categories including certain etch, deposition, lithography, ion-implantation, annealing, metrology, inspection, and cleaning tools, as well as semiconductor-manufacturing-equipment and Footnote 5 foreign-direct-product rules. It said the package was effective on announcement, with a December 31, 2024 compliance date for certain controls. Those rules do not mean every immersion-DUV system is automatically covered.
The Center’s position goes further. It recommends replacing partial DUVi controls with a China-wide ban on DUVi exports, as well as controls on spare parts and servicing. Former U.S. officials Nicholas Brown and Saif M. Khan supported the call reported by the SCMP. This remains a policy recommendation, not an adopted U.S. or allied measure.
Reuters separately reported that a cross-party group of U.S. politicians announced the proposed MATCH Act. Reuters said the proposal would further restrict exports of chipmaking equipment to China, halt equipment servicing, and target SMIC, Hua Hong, Huawei, CXMT, and YMTC. It remains proposed legislation rather than enacted law. Its relationship to the Center’s recommended China-wide DUVi ban is one of direction, not legal identity. A related legislative framing appears in EastFrontier’s earlier coverage of U.S. lawmakers targeting DUV lithography.
For industry participants, the most useful reading of the 343-system estimate is therefore disciplined rather than definitive. It indicates the scale of past access policymakers are trying to weigh, while leaving the state of individual machines and their output unresolved. That difference will matter as governments consider the next controls. EastFrontier has also followed domestic DUV development as related archive context.