Dutch Trade Minister Sjoerd Sjoerdsma traveled to Washington in June 2026 to tell Commerce Secretary Howard Lutnick and members of Congress, in effect, that the United States does not get to write the Netherlands' export control law. His target was the Multilateral Alignment of Technology Controls on Hardware Act — the MATCH Act, introduced in the House as H.R. 8170 and in the Senate as S. 4281 — which would extend US chip-equipment export restrictions to ASML's deep ultraviolet (DUV) immersion lithography tools, on top of the extreme ultraviolet (EUV) machines already barred from China since 2019. "Export control simply works best when countries cooperate out of conviction, rather than when policy is imposed across the border," Sjoerdsma said, calling his own visit "exceptional" and warning that "the stakes for the Netherlands may be very high."
What the Bill Actually Does
The MATCH Act's text, published on govinfo.gov, does not merely tighten the existing US Entity List regime. It instructs US agencies to press allied equipment suppliers — the Netherlands (ASML) and Japan (Tokyo Electron, Nikon, Canon) chief among them — to adopt "countrywide controls on covered semiconductor manufacturing equipment" and a "licensing policy of denial," including for servicing machines already sold and installed in China. If an ally does not fall in line within 150 days, the bill authorizes the US to unilaterally restrict exports from that country using an expanded foreign direct product rule — one that reaches "a foreign-produced item with more than zero percent de minimis controlled United States-origin content." A near-zero threshold is, in practice, no threshold: it is difficult to build a modern lithography machine without a single US-origin component, so the rule gives Washington leverage over equipment it never designed and a company it does not regulate.
That is the extraterritorial reach Sjoerdsma objects to, and the objection is not hollow nationalism. ASML operates under the Netherlands' own 2023 export licensing regime — the Regeling geavanceerde productieapparatuur voor halfgeleiders, effective September 1, 2023, and expanded again in September 2024 under Minister Reinette Klever to cover a broader set of DUV tools (Staatscourant 2024, 29008) — which the Dutch government adopted under EU dual-use rules specifically to align with US concerns after the 2019 EUV restrictions. The Dutch government has tightened the licensing regime three times since 2023 without being told to. The MATCH Act's answer to a country that has already moved is to threaten it with a 150-day clock anyway.
The Case for the Hard Line — Steelmanned
Washington's frustration has a real basis. US officials have watched Chinese fabs like SMIC and YMTC continue advancing on trailing-edge and even some leading-edge nodes using older DUV tools and creative supply-chain workarounds, and they argue that a patchwork of national licensing regimes — reviewed case-by-case, as the Dutch system explicitly is — leaves gaps that a determined, well-funded state actor will find. A single missed license approval, the argument goes, can hand Beijing capability the entire coalition spent years trying to deny. Given how concentrated advanced lithography is in one company in one small country, US legislators reasonably ask why American national security policy should hinge on the discretion of Dutch civil servants applying a foreign statute.
But that logic proves too much. It is also the logic of a country demanding veto power over its allies' domestic regulatory sovereignty whenever it judges their execution insufficiently strict — a standard the US would never accept applied to its own export licensing decisions by, say, the EU. And the mechanism compounds the harm: banning maintenance and servicing of equipment already sold does not claw back capability China already possesses. It mainly threatens the reliability of machines Chinese fabs depend on today, with unpredictable spillover risk. The Dutch government's own comparison point is instructive — China's 2025 rare-earth and chip-related export restrictions caused documented global supply disruptions within weeks. A servicing cutoff invites the same kind of retaliatory chokepoint fight, except this time triggered by the coalition that is supposed to be managing supply chain risk, not creating it.
Why Coalition-Based Controls Beat Unilateral Ultimatums
China accounted for roughly 19% of ASML's net system sales, according to reporting on the company's most recent disclosures — a meaningful but not existential share, and one the Dutch government has already been willing to shrink through its own restrictions. That is precisely the case for the multilateral model the 2023 and 2024 Dutch measures represent: allies converging through their own legal processes, informed by shared intelligence, rather than a 150-day ultimatum backed by a near-zero de minimis threshold that treats sovereign regulators as subcontractors. The Netherlands is not resisting export controls on chip equipment — it has expanded them three times in three years. It is resisting a bill that would let Congress overrule Dutch and EU dual-use law by statute. Congress should tighten enforcement gaps it can find in coordination with The Hague and Tokyo, not legislate as though allied capitals answer to it.