Saif Khan, founding director of the Center for Technology and Statecraft (CTS), and Nick Brown, CTS co-founder and senior fellow, join Gregory C. Allen to unpack their landmark 100+ page report, DUV Immersion Lithography: The Foundation of the US AI Advantage: Closing Gaps in Export Controls to China. Their central finding is that EUV gets the headlines, but the older immersion DUV machines are what China actually uses to make AI chips. China’s stockpile has grown from roughly 50–100 immersion tools in October 2022 to around 340 today. It imported about 90 a year in 2024 and 2025, close to two-thirds of ASML’s global immersion market.
They explain why ASML’s NXT:1980, which can be legally exported to China, is the machine to watch. They also cover how etch and deposition controls are masking the full power of China’s lithography stockpile, and why Chinese indigenization announcements, including the new 28nm prototype, don’t change the strategic picture before the 2030s. Then they lay out their scenario models. Even in an extreme case, China’s current stockpile can’t match US AI chip production through 2035, but continued imports could close the gap or even tip it. Finally, Saif and Nick make the case for a countrywide ban on immersion DUV, the levers the US could pull without new legislation, and what the MATCH Act in the Senate NDAA could mean for the fight.
Read the report at techstatecraft.org/duv.
Chapters
00:00 – 05:35: Meet the Center for Technology and Statecraft and the people behind the report
05:35 – 08:22: What immersion DUV is, and why it matters more than EUV for China’s AI chips
08:22 – 12:56: From Cold War controls to ASML’s near-monopoly: how lithography export controls evolved
12:56 – 17:29: The counterfactual: where would Huawei and SMIC be without EUV controls?
17:29 – 22:45: Three tiers of DUV, the NXT:1980 loophole, and why countrywide beats case-by-case licensing
22:45 – 25:18: What if the US had banned all immersion DUV in 2022? From 50+ machines to ~340
25:18 – 30:02: Why China hasn’t yet unlocked the full power of its lithography stockpile
30:02 – 37:26: Can China build its own? Prototype, commercialization, scale-up, and the 2030s
37:26 – 45:40: The scenario models: when stockpile alone isn’t enough, and when imports tip the balance
45:40 – 50:13: Flops per gigawatt, 90 machines a year, and 100,000 Huawei chips per tool
50:13 – 55:11: Monday morning at BIS: allied controls, light sources, FDPR, de minimis, and the MATCH Act
55:11 – 55:27: Where to find the report
