A warning has been issued that if exports of advanced immersion deep ultraviolet lithography tools (DUVi) to China continue, the AI semiconductor competitiveness of the United States and its allies could weaken or disappear within 5 to 10 years. It also argued that to curb China’s capacity to produce advanced AI chips, export controls should be strengthened on semiconductor manufacturing equipment rather than on the chips themselves.

On Oct. 6, online media outlet Gigazine reported that the Technology & Statecraft Center, a U.S. AI and semiconductor policy research group, made the claim in a recent report. The group said advanced semiconductor manufacturing equipment is essential for producing competitive AI chips, and it assessed that the core of the advantage held by the United States and its allies lies in restricting China’s access to advanced tools.

The report in particular pointed to immersion DUV lithography tools, or DUVi, as a key variable. The United States has so far regulated extreme ultraviolet (EUV) lithography tools and some advanced DUVi, and has allowed exports of some tools with licenses. But the group judged that if advanced DUVi continue to be supplied to China, China could secure sufficient semiconductor production capacity.

The group said it viewed the likelihood as low that China would commercialise advanced lithography tools domestically on a large scale by the mid-2030s. It said how much overseas equipment China secures before then could determine the AI semiconductor production gap. The report warned that if exports continue as they are, the AI semiconductor advantage of the United States and its allies would "shrink or disappear".

The scale of China’s DUVi holdings is also a variable. The group estimated that since 2020 China has secured about 300 DUVi units, centered on ASML’s NXT:1980i. It said the current holdings alone would be insufficient to threaten the United States, but if China continues acquiring NXT:1980i or similar tools at the same pace and deploys them for AI chip production, it could lay the foundation to produce "hundreds of millions of H100-class chips".

The group proposed blocking exports of DUVi to China in principle. Under the existing export control system, dry DUV and some relatively lower-level tools can be exported to China without approval, but it said no tools other than dry DUV should be sent to China.

It also pointed to the current licensing system as a problem. While advanced tools formally require approval for export to China, in practice most are being approved. The group said that to increase the effectiveness of export controls, the system should be strengthened not merely by requiring approval in regulations but by reducing the amount of equipment China actually secures.

It also raised the possibility that China could seek to acquire the tools through third countries. It said that if the Netherlands and Japan respond passively to export controls, the United States could use the Foreign Direct Product Rule (FDPR) to impose additional restrictions. It also proposed applying export control rules to ASML production facilities that use U.S. technology or equipment.

China’s domestic technology development is also a long-term variable. News was reported that a Chinese state-owned company began producing DUV lithography tools in July 2026, but the group forecast that China would have difficulty commercialising advanced lithography tools on a large scale for the time being.

Ultimately, the key to the future contest for AI semiconductor dominance is expected to depend on how much advanced lithography equipment China can secure. Whether the United States will actually tighten DUVi export restrictions and whether it will introduce additional steps to close loopholes in the existing licensing system are expected to be important variables for future semiconductor supply chains and the competitive landscape for AI.