Dutch and Japanese Chip Export Controls Explained: How ASML and Tokyo Electron Rules Line Up With the US
The US can block exports of American chipmaking tools, but it does not make all the tools that matter. The world’s only maker of EUV lithography machines is ASML in the Netherlands. Japan’s Tokyo Electron is a top supplier of the coating, etching and deposition systems found in every advanced fab. Without the Netherlands and Japan on board, US equipment controls on China would leak badly.
Both countries did sign on, starting in 2023. Their rules are narrower than Washington wants, though, and the gaps are where most of the arguments happen. This page explains what each country restricts, how the rules came about and where they still differ from the US.
Why the US needs them
A modern fab runs on hundreds of tool types. The US leads in many (Applied Materials, Lam Research and KLA), but a few are effectively Dutch or Japanese monopolies:
- EUV lithography: ASML only. Needed for leading-edge logic at 5nm-class and below, and increasingly for advanced DRAM.
- Advanced DUV immersion lithography: ASML leads, with Nikon a distant second.
- Coater/developers for lithography: Tokyo Electron holds the overwhelming share.
- Etch, deposition, cleaning and thermal tools: Tokyo Electron, Screen, Kokusai and others compete closely with the US firms.
If only the US restricts a tool category, Chinese fabs can switch to a Japanese or Dutch supplier. That is the hole the 2023 agreements were meant to close. The terms involved are explained in our guide to export control and sanctions acronyms.
The Netherlands: EUV first, then DUV
The Dutch moved in stages.
| Date | Dutch action | What it covers |
|---|---|---|
| 2019 | Export license for ASML EUV to China not granted | No EUV system has ever shipped to China |
| Jan 2023 | Agreement in principle with the US and Japan | Commits to new equipment controls |
| June 30, 2023 | National rule published, effective Sept 1, 2023 | Licenses needed for the most advanced DUV immersion tools (NXT:2000i and newer) |
| Jan 1, 2024 | Dutch revoke some licenses early | Some NXT:1970i and 1980i shipments to China cancelled after US pressure |
| Sept 7, 2024 | Dutch take over licensing of 1970i and 1980i from the US | Puts those older immersion tools under Dutch, not US, licensing |
| Jan 15, 2025 | Further expansion announced (in force April 1, 2025) | Adds certain measurement and inspection equipment and related software |
The Dutch rules are country-neutral on paper. They apply to exports to any destination outside the EU, and licenses are decided case by case. In practice China is the target, and few licenses for the covered tools go there.
The effect on ASML has been unusual. Chinese fabs rushed to buy every tool they still could before the rules tightened, so China’s share of ASML’s system sales jumped rather than fell, reaching close to half in some quarters of 2024. ASML expected that share to come down as the backlog of orders placed before the rules was worked through. For the argument that older DUV tools were never the real chokepoint, see China’s domestic DUV line cut ASML 7%, but DUV was never the chokepoint.
Japan: 23 tool types
Japan’s Ministry of Economy, Trade and Industry (METI) took a different route. In March 2023 it announced that 23 types of chipmaking equipment would need individual export licenses, and the rule took effect on July 23, 2023.
The list covers six broad categories:
- Lithography and exposure, including some EUV-related items
- Etching
- Deposition
- Cleaning
- Thermal processing
- Inspection and testing
Like the Dutch rules, Japan’s controls do not name China. Instead, exports to 42 “friendly” countries (the US, EU members, South Korea, Taiwan and others) get simpler treatment, and exports everywhere else need an individual license. China is the obvious target.
For Tokyo Electron, China became its biggest market in the years right after the rules, again because Chinese fabs kept buying the many tools that remained legal. Mature-node equipment for 28nm and older chips is mostly outside the controls, and China has built a lot of mature-node capacity.
Where the rules still differ from the US
The three sets of rules overlap but they are not the same. The differences matter for companies and for China’s planning.
| Issue | United States | Netherlands | Japan |
|---|---|---|---|
| Names China explicitly | Yes, many rules are China-specific | No, country-neutral | No, but 42 countries get easier treatment |
| Reach over foreign-made items | Yes, through foreign direct product rules | No equivalent | No equivalent |
| Limits on own citizens’ work in Chinese fabs | Yes, “US persons” rule since Oct 2022 | No | No |
| Entity-based restrictions | Entity List, often presumption of denial | Limited | Limited end-user list |
| Servicing installed tools | Restricted for many US tools | Has been a point of US pressure | Has been a point of US pressure |
| Mature-node tools | Mostly allowed | Mostly allowed | Mostly allowed |
Three gaps get the most attention.
Servicing. Thousands of ASML and Tokyo Electron machines are already installed in Chinese fabs. Keeping them running needs spare parts, software updates and field engineers. Washington has pushed both allies to restrict servicing, especially for advanced tools at sensitive fabs.
People. The US bars its citizens and green card holders from supporting advanced chipmaking in China without a license. The Netherlands and Japan have no equivalent.
Extraterritorial reach. When the US widened its FDPR to equipment in December 2024, it exempted tools from the Netherlands and Japan, recognizing their own controls. That exemption is also leverage: if the allies’ rules are seen as too weak, the US can extend its reach over their exports directly.
What it means
For China, the combined rules mean no EUV at all and steadily fewer advanced DUV and process tools. That is why SMIC’s 7nm-class chips, like the one inside Huawei’s Mate 60 (see the Huawei sanctions timeline), rely on older DUV machines and multiple exposures, which is slower and more costly.
It is also why China is pouring money into domestic toolmakers such as Naura, AMEC and SMEE. Several of them are now on the US list themselves, as the Entity List additions tracker shows.
For ASML and Tokyo Electron, the risk is mostly the slope of China demand. Mature-node buying in China has been huge and cannot run at that pace forever.
The broader sequence of US rules these allied controls plug into is in our US chip export controls timeline. Watch for three things: any Dutch or Japanese move on servicing, any extension of US rules to allied-made tools, and how fast Chinese equipment makers close the gap on their own. Related reading on the financing side is our explainer on outbound investment rules.