A Two-Track Approach to Washington
On June 24, 2026, Dutch Minister for Foreign Trade Sjoerd Sjoerdsma signed the Netherlands into Pax Silica, the US-led framework for coordinating AI and semiconductor supply-chain security, in a Washington ceremony alongside US Under Secretary of State for Economic Affairs Jacob Helberg (Government.nl). "The Netherlands plays a unique, leading role in the global chip industry," Sjoerdsma said, framing membership as a way to "strengthen the Netherlands' trading position."
The same week, in the same city, Sjoerdsma was doing the opposite on a related file: lobbying members of Congress against the MATCH Act, a bill that would give the United States unilateral authority to force ASML — the Dutch lithography giant and Europe's most valuable listed company — to stop selling and servicing certain chipmaking tools in China (DutchNews.nl). The juxtaposition is not contradictory so much as diagnostic: The Hague will coordinate with Washington voluntarily, but resists being told what to do by statute.
What the MATCH Act Would Actually Do
The Multilateral Alignment of Technology Controls on Hardware Act — S.4281 in the Senate, H.R.8170 in the House, introduced in early April 2026 by Rep. Michael Baumgartner and Sens. Jim Risch, Pete Ricketts and Andy Kim — cleared the House Foreign Affairs Committee on April 22 as part of what lawmakers called the largest export-control markup in congressional history (Tech Wire Asia). Its core mechanism: if allied governments — named targets include the Netherlands and Japan — don't align their own export rules with Washington's within 150 days, the US can impose restrictions unilaterally on those countries' exports.
For ASML, the practical effect would be a country-wide presumption of denial on deep ultraviolet (DUV) immersion lithography tools sold to China, plus a ban on servicing DUV machines already installed at Chinese fabs including SMIC, Huawei, YMTC, CXMT and Hua Hong. According to the Dutch government's own written response to parliamentary questions, China accounted for 33% of ASML's 2025 system-sales revenue, a share it expects to fall to roughly 20% in 2026 even without new legislation, as a backlog of pre-restriction orders works through the pipeline (Tweede Kamer).
The Case for Tighter Controls, Stated Fairly
The MATCH Act's sponsors have a real argument, not a paranoid one. DUV immersion tools, while a rung below the EUV machines banned since 2019, are still the equipment SMIC and others have used to approach 7nm-class production — nodes good enough for military and advanced AI applications. Export-control regimes built on case-by-case licensing have repeatedly been shown to leak: shell-company purchases, re-routed shipments, and maintenance contracts that keep restricted tools running long after a sale should have been blocked. If Washington believes allied licensing has been too permissive, forcing alignment through statute is a coherent, if blunt, response to a coordination problem that voluntary diplomacy hasn't fully solved.
Extraterritoriality Is the Real Fight
But the Dutch objection isn't really about whether China should get DUV tools — it's about who gets to decide. The government's position, laid out in its Kamervragen response, is that Dutch export policy already applies a "surgical approach based on national security risks," assessing exports case by case rather than through blanket, country-wide bans. Sjoerdsma's formulation is pointed: "each country is responsible for its own export control legislation." A US statute that starts a 150-day countdown clock on a sovereign ally's licensing regime, backed by the threat of unilateral enforcement, is a different kind of instrument than a shared list of controlled technologies negotiated through the Wassenaar Arrangement, the multilateral export-control forum both countries already belong to.
The maintenance provision sharpens the problem. Barring ASML from servicing machines it has already legally sold — under contracts signed before any restriction existed — risks converting an export-control statute into a forced-breach machine, with the Netherlands, not the United States, absorbing the legal and reputational fallout with its own company.
Why the Voluntary Model Should Win
Pax Silica's own design points to the better answer. It is a non-binding declaration with no funding mandate and no enforcement mechanism — deliberately structured as coordination among willing partners rather than a chain of command. That the Netherlands signed it the same week it was resisting the MATCH Act is not opportunism; it's a signal about what kind of alliance actually holds. Allies that feel dictated to look for exits — deeper EU strategic-autonomy pushes, closer coordination with non-US suppliers, quieter foot-dragging on enforcement. Allies that are treated as genuine security partners, with real input into where the line on "chokepoint" technology sits, have every incentive to tighten controls that they helped design.
Washington's export-control gaps with China are real enough to deserve a fix. But a fix that trades a cooperative, self-interested Dutch government for a resentful one — over tools that are already a shrinking and marginal share of ASML's China business — is a worse trade than it looks on paper. The proportionate path is the one Pax Silica already models: coordinate the target list, not the sovereignty.