Recently, US Commerce Secretary Howard Lutnick raised concerns in a meeting with ASML executives: Is there an ASML EUV lithography machine — or at least key components — that may have bypassed export controls and reached mainland China?
Bloomberg reported that US officials say they have evidence, but have not made it public.
ASML’s response was clear: No complete EUV machine is in China.
After the meeting, ASML circulated a document in Washington with key figures:
- There are currently 314 EUV machines worldwide
- Most are in Taiwan, South Korea, and the US (TSMC, Samsung, SK Hynix, Intel)
- None are in mainland China
- Another 26 have been decommissioned and scrapped — also not in China
ASML stressed that an EUV machine weighs 180 tons and has about 100,000 parts. Transport, installation, and maintenance require their engineers. The machines stay connected to headquarters, allowing remote monitoring and the ability to shut them down if needed. They say every machine is fully accounted for.
1. The two sides seem to be answering slightly different questions
The US appears to be asking whether China has gained EUV-level capability or access to critical components. ASML answered that no complete ASML EUV system has gone to China.
It feels like they’re talking past each other.
2. Quick explainer: EUV vs DUV
EUV (extreme ultraviolet) uses a much shorter wavelength, allowing finer patterns on chips — essential for key layers in advanced nodes. DUV (deep ultraviolet) has a longer wavelength, so making fine features requires multiple exposures.
Huawei and SMIC currently rely on DUV multi-patterning to produce 7nm chips. But more exposures mean accumulated errors and lower yields. EUV’s advantage is achieving complex patterns with fewer exposures, improving both speed and yield.
Even with EUV, chips are still built layer by layer — it’s not a single “flash” process.
3. Where do China’s 7nm chips come from?
Mainly three sources:
- Stockpiles ordered by Huawei before tighter restrictions kicked in
- Chips ordered through a related entity (Sophgo, linked to Bitmain) from TSMC — TSMC later terminated the relationship after discovering the end use
- SMIC producing them domestically using existing DUV machines with multi-patterning techniques
TSMC itself used DUV multi-exposure for 7nm in the early days. Once EUV became available and more cost-effective (better yield and speed), it shifted. Some process know-how likely spread through various channels.
Still, using DUV for 7nm requires dozens of exposures — yields are not great.
4. Does China have EUV capability?
A few layers to consider:
- Basic principles:
China operates many DUV machines and understands lithography workflows well. ASML has a large software R&D center in Shenzhen, so the fundamentals are familiar.
- Core components:
This is the tough part. Zeiss precision mirrors, the EUV light source, and high-precision stages are extremely difficult to replicate at the required accuracy.
However, these machines need regular maintenance and part replacements. It’s possible that some critical components could have entered circulation during servicing. ASML can check major modules via the machine’s software, but tracking every single small part would be extremely costly and technically challenging.
So ASML can confidently say “no whole machines,” but hasn’t fully closed the door on component-level questions.
5. The real barrier is the certification system
You can’t just build something and use it. Every part in an ASML machine goes through rigorous engineering certification. Think of the C919 airliner — some cables must be original certified parts, not because they can’t be made, but because they haven’t passed the required validation process.
The certification involves many detailed tests and standards that aren’t fully public. Without participating in the system, it’s hard to know exactly where the bottlenecks are or how to improve.
6. To fully block China would require “three cuts”
- Prevent participation in the supply chain and R&D from the start
- Strictly stop critical components from reaching China
- Use the certification system as a gatekeeper
The second cut is very hard to enforce. Supply chains are deeply intertwined. China was once ASML’s largest market (around 30% of sales in 2024, mostly DUV). ASML has over 1,400 suppliers in Asia, and some materials inevitably involve China.
7. China’s practical advantage: low-cost, fast iteration
Western and Japanese/Korean companies face high costs for each trial — a few failures can hurt badly. China benefits from lower costs in labor, facilities, energy, and materials, plus a complete domestic supply chain. With policy support, it can run multiple test cycles faster and cheaper.
This is similar to China’s high-speed rail story: start with imported systems, test and localize step by step, and reach very high domestic content.
8. Why is the US pressing ASML now?
It may be connected to Huawei’s recent process optimization announcement (sometimes called the “Tao Ding Law” in discussions). The changes are mostly clever reordering of steps — similar to what TSMC did years ago — but they signal that pushing to even more advanced nodes will eventually require EUV-level capability.
The US may have spotted specific supply-chain or technical details worth asking about. ASML is threading a careful line: addressing US concerns while not wanting to lose the Chinese market (still over 20% of sales in 2025).
9. Bottom line
Based on available information, China appears to have developed some form of working EUV capability — not by acquiring complete machines, but likely through reverse-engineering similar systems and incorporating critical components obtained via maintenance, replacement, or decommissioned equipment.
This gets machines running, but it’s still a long way from stable, high-yield mass production of cutting-edge 5nm or 3nm chips. Cost and efficiency remain real hurdles.
The US wants to maintain a technological edge, ASML is balancing commercial realities, and China continues investing and iterating. In a deeply interconnected global supply chain, completely cutting off one side comes at a high cost for everyone.
This story is still unfolding — worth keeping an eye on.
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